TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 11, 2021

On May 13, 2021, the Supreme Court in CIC Services, Inc. v. Internal Revenue Service held that the Anti-Injunction Act did not bar an action to enjoin an IRS listed transaction notice because it allegedly failed to comply with the Administrative Procedures Act (“APA”) notice and comment provisions.  See, https://www.taxlitigator.com/and-now-for-something-completely-different-supreme-court-holds-suit-to-enjoin-irs-notice-not-barred-by-the-anti-injunction-act-by-robert-s-horwitz/.  On the same day, a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 11, 2021

We are pleased to invite you to register now for the 13th Annual NYU Tax Controversy Forum Webinar to be held June 24 and 25.  You do not want to miss this program. Co-Chairs Bryan Skarlatos and Steven Toscher are pleased to announce this year’s NYU Tax Controversy Forum which will feature updates on what the IRS is doing to enhance compliance through […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 10, 2021

We are pleased to announce that Evan Davis, along with Ian M. Comisky, Deborah L. Connor and Andrew Winerman will be speaking at the upcoming 13th Annual NYU Tax Controversy Forum webinar, “Shining a Light on Dirty Money: Corporate Transparency and Anti-Money Laundering Acts of 2020” on Friday, June 25, 2021, 3:30 p.m. – 4:30 p.m. (PST). Last year, Congress passed […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 10, 2021

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 08, 2021

We 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, June 06, 2021

We 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 28, 2021

Whenever 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 27, 2021

The 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 27, 2021

We 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 25, 2021

We 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 25, 2021

I 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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, May 22, 2021

We 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…