We are pleased to announce that Sandra Brown, along with Jonathan Black, Sharyn Fisk and Lois Dietrich will be speaking at the upcoming 13th Annual NYU Tax Controversy Forum webinar, “Focus on Tax Practitioners: Ethical and Penalty Issues” on Thursday, June 24, 2021, 3:00 p.m. – 4:00 p.m. (PST). Tax practitioners are the gatekeepers to the country’s tax system and are […] Read More…
Read MoreWe are pleased to announce that Michel Stein Sandra Brown and Evan Davis will be speaking at the upcoming CalCPA webinar, “Cryptocurrency Tax Compliance in the Post $50,000 Bitcoin World” on Tuesday, June 15, 2021, 9:00 a.m. – 10:00 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting […] Read More…
Read MoreWe are pleased to announce that Steven Toscher and Michel Stein will be speaking at the upcoming CSTC webinar, “New Developments in Cryptocurrency Reporting and Enforcement” on Wednesday, June 9, 2021, 10:00 a.m. – 11:40 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating […] Read More…
Read MoreWhenever I read a new FBAR willful penalty I get a distinct feeling of déjà vu all over again, to quote the great Yogi Berra. Elements: Did the taxpayer have a foreign bank account – check. Did the taxpayer know of the foreign bank account – check Did the taxpayer fail to tell the return […] Read More…
Read MoreThe Biden administration’s vision for increased information reporting, depending on implementation specifics, may have a new obstacle to contend with: the Supreme Court’s recent decision shortening the reach of the Anti-Injunction Act (AIA). In its decision, the Supreme Court gave as one reason why the AIA did not apply was that there were several steps […] Read More…
Read MoreWe are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming Strafford webinar, “High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations” on Wednesday, June 2, 2021, 10:00 a.m. – 11:30 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST). This webinar will discuss the IRS’ recent […] Read More…
Read MoreWe are pleased to announce that Sandra Brown will be speaking at the upcoming 21st Annual Oregon Tax Institute webinar, “John Doe Summonses: A Deeper Look at a Key IRS Information Gathering Tool and What Its Increased Use May Mean to Non-Compliant Taxpayers” on Friday, June 4, 2021, 2:50 p.m. – 3:50 p.m. (PST). In […] Read More…
Read MoreI thought after my last series of blogs on recent FBAR cases that it would be safe to venture into the waters of Title 26 cases. But just when I was starting to work on some blogs on interesting tax cases, a school of Title 31 willful FBAR penalty cases broke the surface, jaws open, […] Read More…
Read MoreWe are pleased to announce that Sandra R. Brown has been named to the list of “Top Women Lawyers of 2021,” by the Daily Journal. The award honors excellent lawyering and leadership skills among women attorneys in California, seeking to recognize attorneys making an impact in the legal profession and cutting-edge legal work in their field. […] Read More…
Read MoreOn May 17, 2021, the Supreme Court issued its unanimous opinion in CIC Services, Inc. v. Internal Revenue Service, holding that a suit challenging an IRS Notice regarding micro-captive insurance companies was not barred by the Anti-Injunction Act (“AIA”).[1] We’ll start with some background. The AIA was enacted shortly after the Civil War, in the […] Read More…
Read MoreYou can go on YouTube and watch the greatest dunks, home runs, touchdowns over and over and over and not pay a cent. How much would you pay to “own” that highlight? For many the answer is tens or hundreds of thousands. NBA Top Shot is officially licensed by the NBA and in little time […] Read More…
Read MoreWe are pleased to announce that Dennis Perez, Michel Stein, and Robert Horwitz will be speaking at the upcoming CalCPA webinar, “Federal and State Residency Issues: Remote Workers and Navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World” on Tuesday, May 25, 2021, 9:00 a.m. – 10:00a.m. (PST). This webinar will guide […] Read More…
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