TAXLITIGATOR Blog
USC Gould School of Law 70th Tax Institute – January 23-25, 2023
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, December 28, 2022
Please join us January 23-25, 2023 for the USC Gould School of Law 2023 Tax Institute at the Millennium Biltmore Hotel, Los Angeles. This is the Institute’s 70th year and the firm is proud to continue our participation. Meet with fellow tax practitioners and address the cutting-edge tax issues affecting all tax professionals. This three-day institute includes discussions, networking opportunities […] Read More…
Read MoreIRS Issues Proposed Regulation on Conservation Easements as Listed Transactions, but that Doesn’t Mean It Is Acquiescing to Court Decisions by ROBERT S. HORWITZ
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, December 20, 2022
In Green Valley Investors, LLC v. Commissioner, 159 T.C. No. 5 (Nov. 9, 2022), the Tax Court invalidated Notice 2017-10, which designated syndicated conservation easements as listed transactions, because it was a legislative rule that was issued without complying with the notice and comment provisions of the Administrative Procedures Act (“APA”). We recently blogged on […] Read More…
Read MoreSTEVEN TOSCHER Elected to Tierra Del Sol Foundation’s Board of Directors
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 19, 2022
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Read MoreHappy Holidays from Hochman Salkin Toscher Perez P.C.
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, December 15, 2022
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CORY STIGILE and PHILIPP BEHRENDT to Speak at Upcoming Beverly Hills Bar Association Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 14, 2022
We are pleased to announce that Cory Stigile and Philipp Behrendt, will be speaking at the upcoming BHBA webinar “The Ins and Outs of Tax Audits,” Tuesday, January 10, 2023, 12:30 p.m. – 1:30 p.m. (PST). This program will go over the fundamentals of tax audits in order to provide business owners, entrepreneurs, and practitioners with the tools and language […] Read More…
Read MoreABA National Institute on Criminal Tax Fraud & Tax Controversy Conference – Tax Court’s Pro Bono Calendar Call
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 12, 2022
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No Equitable Tolling for Deficiency Cases: The Tax Court Holds that the Period of Limitations for Filing a Petition to Redetermine a Deficiency Is Jurisdictional by ROBERT S. HORWITZ
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 05, 2022
In Boechler v Commissioner, 596 U.S. ___, 142 S.Ct. 1493 (2022), the Supreme Court held that the 30-day period for petitioning the Tax Court to review a collection due process determination was not jurisdictional and, therefore, could be equitably tolled. Following the Boechler decision, several bloggers, including me, questioned whether the time period of filing […] Read More…
Read MoreEdward Robbins, Jr. Quoted in Tax Notes
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, November 25, 2022
Ed Robbins quoted in Tax Notes concerning Fahry v Commissioner where petitioner is asserting the Internal Revenue Service does not have assessment authority under the Code for many international penalties. While it sounds like a tax protestor argument, this position has some real statutory legs or shall I say a real lack of statutory legs. Stay tuned. […] Read More…
Read MoreEVAN DAVIS’ Case to be Argued in the Supreme Court
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 23, 2022
In early October 2022, the U.S. Supreme Court accepted Evan Davis’s case for argument. The case, a criminal grand jury matter titled In re Grand Jury, Case No. 21-1397, will answer the question: what test should courts use to determine when dual-purpose communications (where a client seeks both legal and non-legal advice) are protected by the […] Read More…
Read MoreLegality Of Certain IRS Information Reporting Penalties at Issue in The Tax Court and Supreme Court by Edward M. Robbins, Jr.
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 22, 2022
Section 6038 Information Penalties Simultaneous answering briefs were filed on November 8, 2022, with the Tax Court in the case of Farhy v. Commissioner (Docket No. 10647- 21L).[i] The sole issue pending is the IRS’ authority to assess and forcibly collect IRC Section 6038 penalties. Petitioner argues there is no specific assessment authority for 6038 […] Read More…
Read MoreThe Tax Court Gives a Primer on Listed Transactions while Invalidating the Conservation Easement Listed Transaction Notice by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, November 18, 2022
The Supreme Court emphasized that it was not inclined “to carve out an approach to administrative review good for tax law only” in Mayo Found. for Med. Educ. & Rsch. v. United States, 562 U.S. 44, 55 (2011). That the IRS is subject to the Administrative Procedures Act (APA) in the same way as other […] Read More…
Read MoreABA 39th Annual National Institute on Criminal Tax Fraud & Tax Controversy
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 15, 2022
I am very pleased to announce this year’s ABA National Institute on Criminal Tax Fraud & Tax Controversy to be held December 12-14, 2022 at Caesar’s Palace in Las Vegas, Nevada. I am honored again to be serving as Co-Chair with Kathryn Keneally. We look forward to the best programs in the nation on civil […] Read More…
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