TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 24, 2026

We are also pleased to announce that Dennis Perez has been recognized in the upcoming Chambers High Net Worth in the area of Tax: Private Client. Dennis Perez “represents high net worth clients in domestic tax examinations and administrative appeals. “Interviewees praise Perez’s work on leading tax cases in California and the Federal Courts.” Chambers is the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 23, 2026

We are pleased to announce that Steven Toscher has been recognized in the Chambers and Partners, 2026 USA, for strength and expertise in the areas of Tax Fraud and Tax Controversy and the upcoming Chambers High Net Worth in the area of Tax: Private Client. Steven Toscher is “a well-regarded tax practitioner who advises clients […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 22, 2026

Once again, Hochman Salkin Toscher Perez P.C. is proud to be recognized by Chambers and Partners 2026 USA, for strength and expertise in the areas of Tax Fraud and Tax Controversy along with the individual rankings of Steven Toscher, Dennis Perez and Sandra R. Brown. While we are proud of the attorneys who have received individual recognition, as noted below by Chambers, it […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 19, 2026

We are pleased to announce that Edward M. Robbins, Jr., Jonathan Kalinski, and Philipp Behrendt will also be speaking on June 24th at the 2026 Annual Tax Controversy Seminar, Problem Solving Day & BBQ at the Bergen Community College at the Meadowlands. BBQ to follow at The Green at Hackensack Court Square on the following […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 18, 2026

We are pleased to announce that Robert S. Horwitz will be speaking at the upcoming BHBA webinar on The Unitary Business Theory and New Limits on Taxing Nonresident Sole Proprietors on Monday, June 22, 2026, 4:30 p.m. (PST). The Franchise Tax Board has pushed hard to tax nonresidents on amounts the FTB claims is California […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 17, 2026

We are pleased to announce that four of our Principals will be speaking at the upcoming 18th Annual NYU Tax Controversy Forum, June 25-26, 2026, at the Westin New York Time Square, on the following key topics: MICHEL R. STEINChallenging Civil Tax Penalties and Interest Reasonable Cause, 7508A, and MoreJune 25th at 4:30 p.m. (EST) […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 16, 2026

Joseph Garza is a Dallas attorney who allegedly helped clients evade taxes on more than $1 billion of income through a circular flow of funds between the clients and shell service corporations that purported to provide services to the clients’ businesses and shell investment corporations. He was initially charged by the United States with eighteen […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 15, 2026

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming CPAacademy webinar on Tax Relief Under Section 7508A(D) Penalties, Interest & Claims on Thursday, June 18, 2026, 2:00 p.m. – 3:00 p.m. (PST). This program examines the potential impact of Internal Revenue Code §7508A(d), […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 12, 2026

We are pleased to announce that Dennis Perez, Michel R. Stein, and Robert S. Horwitzwill be speaking at the upcoming CalCPA webinar on Navigating Federal and State Tax Residency Issues: IRS Examination Guidance, State Regulations, and Remote Workers on Tuesday, June 16, 2026, 9:00 a.m. – 10:30 a.m. (PST). This webinar will guide tax professionals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 09, 2026

A California nonresident is taxable by California on income earned from sources in California. Where two or more commonly owned companies carry on a trade or business within and outside of California, the net income is allocated and apportioned between California and other states under the Uniform Division of Income for Tax Purposes Act (“UDITPA”). In Appeal […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, June 07, 2026

Hot off the press is the Tax Court’s decision in Paschall v. Commissioner, T.C. Memo. 2026-46, which is the first significant merits decision addressing whether proof-of-stake rewards are taxable when received. The Court held that Alvie and Patricia Paschall had unreported income from Cardano staking rewards credited to Mr. Paschall’s eToro account in 2021. Click […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 05, 2026

The California Office of Tax Appeals (OTA) recently published two precedential sales tax pending decisions that, in practical terms, answered questions regarding personal liability, penalties, and interest abatements for unpaid sales tax. Part I focused on the Appeal of Sundown Entertainment Group, Inc., 2026-OTA-225P. There, the OTA sustained a large sales tax determination after the […] Read More…