TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 10, 2021

The IRS Criminal Investigation division isn’t focusing its enforcement efforts specifically on cannabis businesses, but is instead treating them like any other cash-intensive business, according to a division official. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes in part that “. . . practitioners with cannabis clients might need to keep a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 09, 2021

Steven Toscher recently had the opportunity to moderate a Federal Bar Association panel on the IRS new Office of Fraud Enforcement. While much attention was paid on the panel  to the  unveiling some of IRS Crown Jewels  by the new OFE Director Damon Rowe and it’s “Operation Hidden Jewels” in its cryptocurrency enforcement efforts, Steve […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 05, 2021

The price of Bitcoin rose dramatically in 2020 and even doubled in price since the beginning of 2021. On January 1, 2021, Bitcoin was $29,336.31 and on February 21, 2021, it was $58,012.09. Many who have sold their Bitcoin have made a profit. Where there’s profit, there’s income – and where there’s income, there’s tax.  […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 04, 2021

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance, Reporting Requirements” on Wednesday, March 24, 2021, 10:00 a.m. – 11:50 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST). This CLE/CPE webinar will provide tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 17, 2021

We are pleased to announce that Steven Toscher will be speaking at the upcoming Orange County Estate Planning Council webinar, “When a Tax Case Goes Criminal – How to Avoid It and How to Deal with It” on Tuesday, March 23, 2021, 4:45 p.m. – 6:00 p.m. (PST) While criminal tax prosecutions are at a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 17, 2021

We are pleased to announce that Steven Toscher, along with Fred Murray, Deborah Palacheck and Clifford Scherwinski will be speaking at the upcoming Florida Tax Institute webinar, “Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures” on Thursday, March 11, 2021, 9:25 a.m. – 10:25 a.m. (PST). The IRS has again increased […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 17, 2021

We are pleased to announce that Steven Toscher and Jonathan Kalinski will be speaking at the  upcoming Federal Bar Association webinar: Steven Toscher – “Fraud Enforcement Office,”Friday, March 5, 2021, 11:30 a.m. – 12:30 p.m. (PST) Jonathan Kalinski – “Cannabis is Going National – Opportunities and Pifalls,Friday, March 5, 2021, 1:00 p.m. – 2:00 p.m. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 17, 2021

On December 16, 2020, the Eighth Circuit issued its opinion in Coffey v. Commissioner, holding that a tax return filed with the U.S. Virgin Islands Bureau of Internal Revenue (“VIBIR”) was not a filing with the IRS and, thus, the three year statute of limitations on assessment was not triggered. See https://www.taxlitigator.com/a-return-by-any-other-name-by-robert-s-horwitz/.  On February 10, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, February 13, 2021

In Soboyede v. Comm’r, T.C. Summary Opinion 2021-3, the Tax Court addressed whether the taxpayer’s travel expenses while performing legal work in Washington were incurred “while away from home” such that they could be deducted as ordinary and necessary travel expenses under IRC Section 162.   While this is a non-precedential opinion, it is a helpful […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 08, 2021

Historically, most—if not all—states in the U.S. have not required the disclosure of the beneficial owners of corporations, LLCs, or similar entities formed under the laws of the State.[i]  However, with the enactment of the Corporate Transparency Act (CTA)[ii], as part of the 2021 National Defense Authorization Act, the non-disclosure approach has come to an […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 03, 2021

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Strafford webinar, “Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain, Determining Character of Gain and Basis in Mined Currency, Recognizing Filing Obligations and Prior Noncompliance” on Thursday, February 25, 2021, 10:00 a.m. – 11:50 a.m. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 03, 2021

Many businesses either have closed or will be forced to close due to the lockdowns imposed during the COVID-19 pandemic, Closing a business can result in the loss of jobs, a loss of the business owner’s livelihood and the destruction of the business owner’s credit rating.  It can also have adverse tax consequences in the […] Read More…