TAXLITIGATOR Blog

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 10, 2023

Dear Colleague- We cordially invite you to save the date for this years UCLA Extension Tax Controversy Institute which will be live this year and held on October 26, 2023 at the Beverly Hills Hotel in Beverly Hills, California.  The Institute is entering its 39th year and is recognized as one of the top tax controversy […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 08, 2023

We are pleased to announce that Michel Stein, Evan Davis and Philipp Behrendt will be speaking at the upcoming CPA Academy webinar “New Developments in Cryptocurrency: Reporting and Enforcement,” Thursday, May 11, 2023, 8:00 a.m. – 9:00 a.m. (PST). This program will provide tax advisers and compliance professionals with a practical look at IRS guidance for calculating […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 03, 2023

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation,” Thursday, May 4, 2023, 10:00 a.m. – 11:50 a.m. (PST). The IRS Large Business and International Division is auditing high net worth individuals and their […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 24, 2023

The IRS Office of Chief Counsel issued Chief Counsel Advice (“CCA”) 202316008 last Friday regarding the tax consequences of holding a native token to a blockchain distributed ledger that is undergoing a protocol upgrade. Click Here for Full Article

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 17, 2023

The Tax Court has determined that the IRS lacks authority to assess penalties under IRC § 6038(b) for failing to file Forms 5471, in a recent decision, Farhy v. Commissioner, 160 T.C. No. 6 (T.C. April 3, 2023). As further held by the court, absent such an assessment, the IRS has no administrative authority to pursue […] Read More…