TAXLITIGATOR Blog

The IRS Throws Down the Gauntlet to Certain Large Partnership Basis-Shifting Transactions by ROBERT S. HORWITZ and MICHEL R. STEIN

The IRS Throws Down the Gauntlet to Certain Large Partnership Basis-Shifting Transactions by ROBERT S. HORWITZ and MICHEL R. STEIN

Consistent with its efforts to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, and large corporations, on June 17, 2024, the IRS unveiled a series of documents taking aim at basis shifting transactions by related-party partnerships. These documents are: Click Here for Full Article

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EDWARD M. ROBBINS, JR. to Speak at Upcoming Agostino & Associates International and Domestic Tax Controversy Update Seminar

EDWARD M. ROBBINS, JR. to Speak at Upcoming Agostino & Associates International and Domestic Tax Controversy Update Seminar

We are pleased to announce that Edward M. Robbins, Jr. will also be speaking on June 26th at the Agostino & Associates International and Domestic Tax Controversy Update at the Bergen Community College at the Meadowlands. BBQ to follow at The Green at Hackensack Court Square on the topic of Farhy Update, Aroeste, Malta Pensions and what it portends for IRS […] Read More…

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U.S. Supreme Court Rules Life Insurance Proceeds Earmarked for a Share Redemption Are Not Offset by the Redemption Obligation for Estate-Tax Purposes by ROBERT S. HORWITZ and LUKE RYAN

U.S. Supreme Court Rules Life Insurance Proceeds Earmarked for a Share Redemption Are Not Offset by the Redemption Obligation for Estate-Tax Purposes by ROBERT S. HORWITZ and LUKE RYAN

In Connelly v. United States, the U.S. Supreme Court examined an estate-tax issue involving how to value life insurance proceeds received by a closely held corporation upon a principal shareholder’s death. Typically, such proceeds are used by the corporation to buy back shares from the deceased shareholder’s estate, thereby keeping the corporation in the family. The parties […] Read More…

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MICHEL R. STEIN and SANDRA R. BROWN to Speak at Upcoming NYU 16th Annual Tax Controversy Forum

MICHEL R. STEIN and SANDRA R. BROWN to Speak at Upcoming NYU 16th Annual Tax Controversy Forum

We are pleased to invite you to the  16th Annual NYU Tax Controversy Forumto be held June 27 and 28Westin New York, Times Square You do not want to miss this program. Two of our principals will be speaking on the following topics: Michel R. SteinChallenging Civil Penalties – Recent DevelopmentsJune 27 Sandra R. BrownHandling […] Read More…

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MICHEL R. STEIN and SANDRA R. BROWN to Speak at Upcoming Agostino & Associates International and Domestic Tax Controversy Update Seminar

MICHEL R. STEIN and SANDRA R. BROWN to Speak at Upcoming Agostino & Associates International and Domestic Tax Controversy Update Seminar

We are pleased to announce that Michel R. Stein and Sandra R. Brown will be speaking on June 26th at the Agostino & Associates International and Domestic Tax Controversy Update at the Bergen Community College at the Meadowlands. BBQ to follow at The Green at Hackensack Court Square on the following topics: Michel R. SteinState and Local Tax Updates  Sandra R. BrownIRS […] Read More…

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Hochman Salkin Toscher Perez 2024 Chambers USA Top Ranked

Hochman Salkin Toscher Perez 2024 Chambers USA Top Ranked

We are pleased to announce that once again HOCHMAN SALKIN TOSCHER PEREZ P.C. and it’s Managing Principal Steven Toscher have been recognized by Chambers and Partners, 2024 USA, for its strength and expertise in the areas of Tax Fraud and Tax Controversy.  Additionally, we are pleased to announce that three of the firm’s principals, Steven Toscher, Dennis […] Read More…

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EVAN DAVIS, ROBERT S. HORWITZ AND JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar on Continuing Impact of Notable Tax Cases – June 21, 2024

EVAN DAVIS, ROBERT S. HORWITZ AND JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar on Continuing Impact of Notable Tax Cases – June 21, 2024

We are pleased to announce that Evan Davis, Robert S. Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Continuing Impact of Notable Cases: Applying Landmark Tax Decisions to Current Tax Matters” Friday, June 21, 2024, 10:00 a.m. – 11:50 a.m. (PST). Landmark tax cases charted the course for tax calculations and continue to […] Read More…

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MICHEL STEIN to Speak at Upcoming San Fernando Valley Bar Association Webinar

We are pleased to announce that Michel R. Stein will be speaking at the upcoming SVBA webinar “IRS Enforcement Priorities for 2024 and Beyond” Tuesday, June 18, 2024, 12:00 p.m. (PST). Michel Stein will lead a discussion on what tax practitioners can expect from the Internal Revenue Services’ audit priorities and enforcement action after the Inflation […] Read More…

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Eleventh Circuit Shoots Down IRS Conservation Easement Listed Transaction Notice for Failure to Comply with Administrative Procedures Act by ROBERT S. HORWITZ

Eleventh Circuit Shoots Down IRS Conservation Easement Listed Transaction Notice for Failure to Comply with Administrative Procedures Act by ROBERT S. HORWITZ

Not many years ago the government and most practitioners viewed the Anti-Injunction Act as presenting an almost insurmountable barrier to challenges to IRS regulations and rulings. That view began to change with Mayo Foundation for Medical Education & Research v United States, 562 U.S. 44 (2011), which recognized that IRS regulations are subject to review in […] Read More…

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The Tax Court Holds the IRS Is Bound by Its Own Regulations (and TEFRA Still Lives) by ROBERT S. HORWITZ

The Tax Court Holds the IRS Is Bound by Its Own Regulations (and TEFRA Still Lives) by ROBERT S. HORWITZ

In 2015 Congress enacted the Bipartisan Budget Act of 2015 (“BBA”) that, among other things, repealed the TEFRA partnership audit provisions and replaced them with BBA partnership audit provisions effective for partnership tax years beginning after December 31, 2017. Both the TEFRA and BBA partnership audit provisions provided for an audit and adjustments at the partnership […] Read More…

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STEVEN TOSCHER, SANDRA R. BROWN and ROBERT HORWITZ to Speak at Upcoming CalCPA Webinar on IRS Scrutiny of ERCs

STEVEN TOSCHER, SANDRA R. BROWN and ROBERT HORWITZ to Speak at Upcoming CalCPA Webinar on IRS Scrutiny of ERCs

We are pleased to announce that Steven Toscher, Sandra R. Brown and Robert Horwitz will be speaking at the upcoming CalCPA webinar “IRS Scrutiny of ERCs” Tuesday, June 11, 2024, 9:00 a.m. – 10:30 a.m. (PST). The employee retention credit, enacted as part of the CARES Act, is a US federal tax credit that provides an […] Read More…

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USD School of Law – RJS LAW Tax Institute Awards The Richard Carpenter Excellence in Tax Award to SANDRA R. BROWN

USD School of Law – RJS LAW Tax Institute Awards The Richard Carpenter Excellence in Tax Award to SANDRA R. BROWN

We are pleased to announce that Sandra R. Brown will be receiving the prestigious Richard Carpenter Excellence in Tax Award from the USD School of Law – RJS LAW Tax Controversy Institute. The Award is being presented at the 9th Annual USD School of Law – RJS LAW Tax Institute taking place July 19th in San […] Read More…

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