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STEVEN TOSCHER quoted in Tax Notes “Cryptocurrency Customer Compliance” by Lee A. Sheppard

Cryptocurrency is an East Coast versus West Coast problem. On the West Coast, proponents  believe they’re creating a brave new world, connecting people, enabling the unbanked, with their vague good intentions marred by a belief that Washington’s rules don’t apply to them. On the East Coast, business and government are controlled by financiers, and there are rules.  Cryptocurrency is a financial instrument, […] Read More…

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Law360 Quotes MICHEL STEIN: 3 Ways To Disclose Cryptocurrency Transactions To The IRS

The Internal Revenue Service has made cryptocurrency tax compliance one of its top priorities and has recommended that virtual currency users come clean  to the agency if they haven’t disclosed transactions in the past. While filing an amended return along with paying all tax and interest due is generally recognized as a way to correct noncompliance, there are […] Read More…

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Tax Court Update: Majority Holds Section 280E Is Constitutional, But Three Judges Join In Persuasive Dissent by JONATHAN KALINSKI

In a court reviewed opinion[1], a divided Tax Court held that IRC section 280E is not a penalty and therefore does not violate the Eighth Amendment prohibition on excessive fines.  This case provided a different spin on the usual 280E challenges and although the Court ruled that 280E was constitutional, there were three judges who […] Read More…

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STEVEN TOSCHER to speak at the Western Conference on Tax Exempt Organizations at the Convene

We are pleased to announce that Steven Toscher, will be speaking on “You can convince the IRS Your Client is Right- Some Helpful Suggestions to Resolve EO Controversies” at this year’s Western Conference on Tax Exempt Organizations, December 5th and 6th at the Convene, Los Angeles. Click Here for more information.  

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SANDRA BROWN to speak at the California Tax Bar and California Tax Policy Conference, Hyatt Regency, Mission Bay

We are pleased to announce that Sandra Brown, will be speaking on “What Do You Mean There Is a $10,000 Penalty” at this year’s California Tax Bar and California Tax Policy Conference, Friday, November 8th at the Hyatt Regency, Mission Bay.  Click Here for more information. This panel will discuss reporting requirements and penalties relating […] Read More…

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STEVEN TOSCHER and DENNIS PEREZ to speak at the CalCPA 2019 Federal, State, Local & International Tax Conference – Sheraton Hotel, Universal City

We are pleased to announce that two of our principals will be speaking at the upcoming CalCPA 2019 Federal, State, Local & International Tax Conference, November 21-22, 2019 at the Sheraton, Universal City. Stay on top of the latest developments surrounding California, international and federal tax standards and regulations when you attend this conference. Sessions […] Read More…

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Procedures for Coordination of Cases Involving Virtual Currency

This Notice alerts Chief Counsel attorneys to procedures for working and coordinating cases with issues involving virtual currency, including digital assets, digital currency, crypto-assets, and cryptocurrency. These cases may involve information received from various third-party sources, such as information returns, and information received from a summons of a virtual currency exchange. They may involve a […] Read More…

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AOD 2019-03: Non-Acquiescence to Tax Court Ruling Regarding the Tax Treatment of a Franchise Transfer – By SANDRA BROWN and GARY MARKARIAN

On October 11, 2019, the IRS announced its non-acquiescence with the United States Tax Court’s holding in GreenTeam Materials Recovery Facility PN. [3]  In this case, the court held that (1) the sales of businesses which had local government service contracts were considered franchises pursuant to I.R.C. §1253(a); and (2) the sale of franchises were allowed capital-gains […] Read More…

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SANDRA BROWN to speak at the NYU 78th Institute on Federal Taxation

We are pleased to announce that Sandra Brown, will be speaking on “From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Update” at this year’s NYU 78th Institute on Federal Taxation, Sunday, October 20th at the Grand Hyatt, New York and Sunday, November 10th at the Fairmont Hotel, San Francisco. Click Here for more […] Read More…

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MICHEL STEIN to speak at the NYU 78th Institute on Federal Taxation

We are pleased to announce that Michel Stein, will be speaking on “Ethics : When Are You Crossing A Line? Real-Life Ethical Issues in Everyday Tax Practice” at this year’s NYU 78th Institute on Federal Taxation, Thursday, November 14th at the Fairmont Hotel, San Francisco. Click Here for more information. How sure do you have to be before […] Read More…

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Is ‘Corporate America’ Looking at Increased Tax Enforcement? by STEVEN TOSCHER, SANDRA BROWN and GARY MARKARIAN

Is ‘Corporate America’ Looking at Increased Tax Enforcement? by STEVEN TOSCHER, SANDRA BROWN and GARY MARKARIAN

Recent changes in federal tax law, along with announcements from the Internal Revenue Service (IRS), have provided more than subtle signals that the federal taxing authorities are looking to increase their focus on big business, sometimes referred to as ‘Corporate America’. Signs can be gleaned from provisions included in the recently passed Taxpayer First Act […] Read More…

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UCLA 35th Annual Tax Controversy Conference – Message from STEVEN TOSCHER, Institute Chair

For THIRTY-FIVE YEARS the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation.  This year, I am again honored and privileged to serve as Chair of The Annual Tax Controversy Institute. Institute Chair Emeritus. The Institute was founded by Eugene “Gene” […] Read More…

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