TAXLITIGATOR Blog
8th Annual USD School of Law – RJS LAW Tax Controversy Institute
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Tuesday, August 01, 2023
Our partners, Dennis Perez and Sandra Brown, had the privilege of speaking in San Diego on Friday at the 8th Annual USD School of Law- RJS LAW Tax Controversy Institute. Joining Dennis Perez on the Government Loans Panel, which provided an in depth focused on PPP, EIDL and ERC audit and fraud issues, were AUSA Dylan […] Read More…
Read MoreSTEVEN TOSCHER, MICHEL STEIN and PHILIPP BEHRENDT to Speak at Upcoming CalCPA Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 28, 2023
We are pleased to announce that Steven Toscher, Michel Stein, and Philipp Behrendt will be speaking at the upcoming CalCPA webinar “Cryptocurrency Compliance 2023,” Tuesday, August 8, 2023, 9:00 a.m. – 10:00 a.m. (PST). Keep abreast of the IRS’s continuous efforts to enhance compliance in the crypto space. Join us for a practical look at the […] Read More…
Read MoreEVAN DAVIS and CORY STIGILE to Speak at Upcoming CalCPA 2023 Annual Income Tax Seminar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 27, 2023
Please join us July 28, 2023 for the CalCPA 2023 Annual Income Tax Seminar. We have an excellent line up of programs – How to Help an Individuals with Unreported or Misreported Crypto Transactions(8:05 a.m. – 9:25 a.m. PST)Featuring Evan Davis R&D Credit Hot Topic and California Considerations(1:05 p.m. – 2:20 p.m. PST)Featuring Cory Stigile The […] Read More…
Read MoreIRS Steps Up Civil and Criminal Tax Enforcement Regarding Employee Retention Credit by STEVEN TOSCHER and PHILIPP BEHRENDT
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 27, 2023
The Employee Retention Credit (ERC) has been a lifeline for businesses struggling during the COVID-19 pandemic. Designed to provide financial assistance to eligible employers who kept their workforce employed during times of economic hardship, the ERC has proven to be a vital source of support for many. However, with its increasing popularity, aggressive marketing tactics, […] Read More…
Read MoreJONATHAN KALINSKI Quoted in Tax Notes
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 26, 2023
Jonathan Kalinski quoted in Tax Notes article on newly filed Tax Court cases challenging the IRS’ position in applying IRC Section 280E to Offers in Compromise for marijuana businesses. Offers in Compromise are challenging for marijuana businesses because the IRS uses 280E disallowed expenses in determining collection potential, creating a phantom cash problem. “The fiction of […] Read More…
Read MoreSTEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming CPA Academy Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 24, 2023
We are pleased to announce that Steven Toscher, Michel Stein, and Sandra Brown will be speaking at the upcoming CPA Academy webinar “Tax Controversy Hot Topics,” Tuesday, July 25, 2023, 8:00 a.m. – 9:00 a.m. (PST). This webinar will cover critical practice and procedural issues facing practitioners, including IRS priorities, the new emphasis on fraud investigations, […] Read More…
Read MoreDENNIS PEREZ and SANDRA BROWN to Speak at Upcoming USD School of Law – RJS Law Tax Controversy Institute
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 24, 2023
Please join us July 28, 2023 for the USD School of Law – RJS Law Tax Controversy Institute at the San Diego Knauss Center for Business Education, Nexus Theater University of San Diego. We have an excellent line up of programs – A Guide to IRS Criminal Tax Investigations and Prosecutions Featuring Sandra Brown IRS Cares about […] Read More…
Read MoreThird Circuit Holds the Ninety-Day Period for Petitioning the Tax Court for Redetermination Is Not Jurisdictional by ROBERT S. HORWITZ and PHILIPP BEHRENDT
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 21, 2023
For more than 85 years the Tax Court, its predecessor, the Board of Tax Appeals, and those courts of appeal that addressed the issue, held that the statute of limitations for filing a petition for redetermination was jurisdictional. When a prerequisite for a lawsuit is jurisdictional, it means that if the prerequisite has not been met, […] Read More…
Read MorePuerto Rico Tax Break Controversy: IRS Targets Crypto Traders, Hedge Fund Managers, and other Wealthy Individuals by PHILIPP BEHRENDT
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 12, 2023
Puerto Rico has been offering tax incentives to wealthy individuals, hedge fund managers, and cryptocurrency traders since 2012. These tax incentives have allowed them to legally avoid paying federal income tax and certain other taxes. However, recent developments have brought these tax breaks under scrutiny, with US prosecutors and IRS agents launching criminal and civil […] Read More…
Read MoreSTEVEN TOSCHER Quoted in Tax Notes
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 12, 2023
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MICHEL STEIN, EDWARD ROBBINS, JR. and SANDRA BROWN to Speak at Upcoming CalCPA Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 11, 2023
We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Sandra Brown will be speaking at the upcoming CalCPA webinar “Form 8300 Reporting/Cash Intensive Business Audits,” Tuesday, July 18, 2023, 9:00 a.m. – 10:00 a.m. (PST). The law requires that trades and businesses report cash payments of more than $10,000 to the federal government […] Read More…
Read MoreAmerican Bar Association Appoints Sandra Brown and Jonathan Kalinski
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 10, 2023
We are very pleased to announce that Sandra R. Brown has been appointed vice chair of the Section’s Civil and Criminal Tax Penalties Committee for the 2023-2024 term. Sandra’s selection as a committee vice chair and as a Section leader represents recognition by her peers of her abilities and contributions to the work of the Section. […] Read More…
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