TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 12, 2023

HOCHMAN SALKIN TOSCHER PEREZ P.C. is proud to be recognized by Chambers and Partners as one of only three top tier law firms in its U.S. 2023 High Net Worth Guide in the category of Tax: Private Client, as well as a top firm nationwide in the Tax Controversy and Tax Fraud areas. Chambers concluded that […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 06, 2023

We are pleased to announce that Steven Toscher and Evan Davis will be speaking at the upcoming CalCPA webinar “Defending Civil Fraud Case in light of the new IRS Office of Civil Fraud 2023,“ Tuesday, June 13, 2023, 9:00 a.m. – 10:00 a.m. (PST). In September 2020, the IRS created the Office of Fraud Enforcement (OFE) […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 05, 2023

The FTB issued Notice 2023-02 (Notice) on May 31, 2023 providing taxpayers a time-limited opportunity to resolve tax matters relating to potentially abusive Micro-captive Insurance (MCI) and Syndicated Conservation Easement (SCE) Transactions in return for zero or reduced penalties.   Click Here for Full Article

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 01, 2023

We are very pleased to announce that on May 18, 2023, following the success of the firm’s participation in the Taxation Section of the California Lawyers Association’s “DC Delegation,” the following principals and associates of Hochman Salkin Toscher Perez P.C. were sworn in as members of the Supreme Court of the United States by Chief […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 31, 2023

We are pleased to announce that Dennis Perez, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CPA Academy webinar “Resolving Employment Tax Disputes,” Tuesday, June 6, 2023, 2:00 p.m. – 3:00 p.m. (PST). The IRS is increasing civil and criminal enforcement against taxpayers who fail to comply with withholding and remitting of employment […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 30, 2023

An amendment to the U.S. Sentencing Guidelines Manual that takes effect November 1 will include a new two-level reduction for true first offenders having their first contact with the criminal justice system. The amendment, subject to certain exceptions, will apply to offenders with no criminal history points, including offenders with no prior convictions. In adopting this […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 23, 2023

I thought you would be interested in the following story from The Wall Street Journal. Click Here for Link to the Article Download the Wall Street Journal app here: WSJ. Steven Toscher specializes in civil and criminal tax controversy and litigation. He is a Certified Tax Specialist in Taxation, the State Bar of California Board of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 22, 2023

We are pleased to invite you to register now for the 15th Annual NYU Tax Controversy Forum to be held June 8 and 9 Westin New York, Times Square You do not want to miss this program. Two of our principals will be speaking on the following topics: Sandra Brown Employee Retention Credit Audits and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 18, 2023

We are pleased to announce that Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar “Handling Partnership Examinations – WYNTK About New Partnership Procedural Rules,” Tuesday, May 23, 2023, 9:00 a.m. – 10:00 p.m. (PST). This webinar will cover practical considerations for partners and advisers to partnerships operating under the new partnership […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 17, 2023

At the end of last year, the IRS has established a digital asset project office to address crypto-related issues, and it has already begun business. The move reflects the IRS’s growing recognition of the importance of cryptocurrencies and the need for clear guidelines for their taxation.[1] Julie Foerster, who leads the office, recently spoke at […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 15, 2023

We are pleased to announce that Edward M. Robbins, Jr. and Jonathan Kalnski will be speaking at the upcoming Beverly Hills Bar Association webinar “IRS International Penalties After Farhy,” Thursday, May 18, 2023, 12:00 p.m. – 1:30 p.m. (PST). On April 3, 2023, the United States Tax Court, in Farhy v. Commissioner held that the IRS has […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 12, 2023

We are very pleased to announce that Sandra R. Brown, Robert Horwitz, Michel Stein, Edward M. Robbins, Jr., Philipp Behrendt, Gary Markarian, and Michael Greenwade will be part of the Taxation Section of the California Lawyers Association’s “DC Delegation” on May 16-17, 2023, in Washington D.C. For over 30 years, the Taxation Section has annually […] Read More…