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It Still Lives!!  Recent Opinions in Two Willful FBAR Penalty Cases by ROBERT S. HORWITZ

It’s been so long since I have blogged about FBAR cases I almost forgot they even existed.  This is probably the effect of age.  But decisions in two recent cases show that FBAR willful penalty cases are still alive and reflect that courts are not blindly accepting the Government’s “pushing the envelope” theories.  Both cases […] Read More…

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Tax Court Update: Welcome to the Future- The Court Adopts Procedures for Remote Proceedings by JONATHAN KALINSKI

Like much of the country, the Tax Court is taking its business online, adopting procedures for remote proceedings on May 29 by issuing Administrative Order No. 2020-02.  Since March 11, when the Tax Court started cancelling trial sessions, court business has virtually stopped.  The Tax Court building in Washington, D.C. itself has been closed since […] Read More…

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NYU 12th Annual Tax Controversy Webinar – June 18-19, 2020

We are pleased to invite you to the NYU 12th Annual Tax Controversy Forum Webinar to be held June 18 and 19.  This year all registrations are complimentary.  As set forth below, Co-Chairs Bryan Skarlatos and Armando Gomez have assembled an all star group of Government speakers and it will be a great opportunity to learn […] Read More…

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MICHEL STEIN to speak on PPP Loans: Completing Loan Forgiveness Applications, Handling the Latest Q&As and other Recent Guidance

We are pleased to announce that our principal Michel Stein will be speaking at the upcoming Beverly Hills Bar Association webinar on PPP Loans: Completing Loan Forgiveness Applications, Handling the Latest Q&As and other Recent Guidance, Thursday, June 4, 2020, 3:00 pm-4:30 pm. Coronavirus Aid, Relief and Economic Security Act (CARES Act) brought us the […] Read More…

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STEVEN TOSCHER quoted in Tax Notes Article on Appointment of National Fraud Counsel

Longtime IRS attorney Carolyn Schenck has been selected to advise the agency’s new fraud enforcement program. Steven Toscher of Hochman Salkin Toscher Perez PC said Schenck’s appointment suggests a “continued and sustained commitment by the IRS to detect and deter tax fraud,” and that the appointment of Schenck, along with Rowe and O’Dell, will yield […] Read More…

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9th Circuit Confirms Plea Agreements Are Worth the Paper They’re Printed On By EVAN J. DAVIS

Most federal criminal cases end in a written plea agreement, and tax cases are no exception. In plea negotiations, prosecutors wield enormous power and can effectively dictate the terms to most defendants. The plea agreements are largely district-specific, boilerplate documents that even individual prosecutors can’t modify outside of the factual basis, minor adjustments to appellate […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives, Tuesday, May 26, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. All tax practitioners need to […] Read More…

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STEVEN TOSCHER quoted in Tax Notes Regarding Recent PPP Prosecutions

Applicants who clearly lied in their applications for the Paycheck Protection Program’s (PPP) tax-free forgivable loans will make better targets for criminal investigation than those who don’t fit lawmakers’ ideas of the program’s intended beneficiaries. “I’m sure there are some blatantly false [statements on PPP loan applications], and I think that is where it’s going […] Read More…

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DENNIS PEREZ, MICHEL STEIN, ROBERT HORWITZ and SANDRA BROWN to speak on What Professionals Need to Know About PPP Loans and Employee Retention Credit

We are pleased to announce that three of our principals Dennis Perez, Michel Stein, Robert Horwitz and Sandra Brown will be speaking at the upcoming CalCPA webinar on What Professionals Need to Know About PPP Loans and Employee Retention Credit, Tuesday, May 19, 2020, 9:00 a.m. – 10:00 a.m. PST. The panel will discuss the tax […] Read More…

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There’s No Getting Around the Pay First, Litigate Later Rule for California Taxes by ROBERT HORWITZ

Most tax professionals are familiar with the Supreme Court’s Flora decision: a taxpayer has to pay in full a tax assessment plus penalties and interest before you can bring a refund suit.  California has had a similar rule, which has been part of the California Constitution since 1913.  Article XIII, sec. 32 of the California […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques, Thursday, June 18, 2020, 1:00 pm-2:30 pm EST, 10:00 am-11:30 am PST. This CLE/CPE webinar will provide […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to speak on Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming CPAacademy webinar on Developments in Cryptocurrency – Reporting and Enforcement, Wednesday, June 3, 2020, 3:00 pm PDT; 2:00 PST. The Internal Revenue Service (IRS) launched a “soft letter” campaign advising taxpayers believed […] Read More…

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