TAXLITIGATOR Blog

13th Annual NYU Tax Controversy Forum to be held June 24 and 25, 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…

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EVAN DAVIS to Speak at Upcoming Webinar on Shining Light on Dirty Money: Corporate Transparency and Anti-Money Laundering Acts of 2020

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…

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SANDRA BROWN to Speak at Upcoming Webinar on Focus on Tax Practitioners: Ethical and Penalty Issues

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…

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MICHEL STEIN, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming Webinar on Cryptocurrency Tax Compliance in the Post $50,000 Bitcoin World

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…

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STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming Webinar on New Developments in Cryptocurrency Reporting and Enforcement

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…

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FBAR Willful Cases Are Similar to Groundhog Day by ROBERT S. HORWITZ

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…

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ROBERT HORWITZ Weighs in and Quoted in Tax Notes on the Scope of the Supreme Court’s Recent Decision in CIC and the Potential Impact on International Information Reporting Penalties and Proposals for More Expansive Information Reporting

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…

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DENNIS PEREZ, SANDRA BROWN and CORY STIGILE to Speak at Upcoming Webinar on High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations

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…

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SANDRA BROWN to Speak at Upcoming Oregon Tax Institute on John Doe Summonses: A Deeper Look at a Key IRS Information Gathering Tool and What Its Increased Use May Mean to Non-Compliant Taxpayers

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…

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Just When You Thought It Was Safe to Go Back in the Water, FBAR Style by ROBERT S. HORWITZ

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…

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Congratulations to our Partner SANDRA BROWN for being selected to be one of the 2021 Top Women Lawyers in California

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…

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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 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…

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