TAXLITIGATOR Blog

SANDRA BROWN to Speak on From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update

We are pleased to announce that Sandra Brown along with Mark Allison, Larry Campagna, Guinevere Moore and Carolyn Schenck will be speaking at the upcoming NYU 79th Virtual Institute on Federal Taxation webinar, “From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update” on Monday, November 16, 2020, 1:30 p.m. – 4:30 […] Read More…

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UCLA 36th Annual Tax Controversy Virtual Institute -October 20, 2020

Please join Michel Stein as he moderates a panel: LB&I’s New High Wealth Examinations-Is there Really Gold in Them Hills along with Holly Paz, IRS Director of Pass-Through Entities, LG&I, Michael Cohen, DeCastro West, Chodorow and Philip Wilson, Marcum, LLP. The program’s learning objectives include: Learn about the Global High Wealth Group audit program Better Understand the Global High Wealth Group examination […] Read More…

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UCLA 36th Annual Tax Controversy Virtual Institute -October 20, 2020

Please join Sandra R. Brown, former Acting United States Attorney, as she moderates a panel featuring IRS Director of Fraud Enforcement Damon Rowe and IRS CI Special Agent in Charge Ryan Korner, entitled “What Every Practitioner Needs to Know to Protect Their Clients and Themselves From Civil Fraud Penalties and Criminal Investigations”, to be webcast […] Read More…

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STEVEN TOSCHER, DENNIS PEREZ and CORY STIGILE to Speak on High Net Worth Audits

We are pleased to announce that Steven Toscher, Dennis Perez, and Cory Stigile will be speaking at an upcoming Spidell webinar, “High Net Worth Audits” on Wednesday, October 21, 2020, 10:00 a.m. – 12:00 p.m. PST The Global High Wealth Group is an industry group created by the IRS LB&I in 2009. The purpose of the Global […] Read More…

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STEVEN TOSCHER DENNIS PEREZ and MICHEL STEIN to Speak on High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance

We are pleased to announce that Steven Toscher, Dennis Perez and Michel Stein will be speaking at an upcoming Strafford webinar, “High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance” on Thursday, October 22, 2020, 1:00 p.m. – 2:30 p.m. EDT/ 10:00 a.m. – 11:30 a.m. PST The IRS has increased […] Read More…

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What Makes a Failure to File Your Tax Returns a Felony? by SANDRA BROWN

As Benjamin Franklin once wrote, “in this world nothing can be said to be certain, except death and taxes.” For any U.S. citizen or resident with annual income in excess of a statutorily determined amount, the requirement to file a tax return is not only certain, but is a legal obligation. Contrary to popular myth, […] Read More…

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JONATHAN KALINSKI Quoted in in Tax Notes Article Regarding IRS and the Cannabis Industry

IRS attempts to help cannabis industry taxpayers understand their tax obligations likely signal an increased interest in enforcement, according to practitioners. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes that the information in the FAQ is well known to the state-legal marijuana industry, but “the IRS doesn’t just pop up —even though […] Read More…

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SANDRA BROWN Quoted in in Wonderful LAW360 Article on Justice Ginsburg’s Legacy in Tax Cases

Law360 — Included in Justice Ruth Bader Ginsburg’s monumental legacy are several tax opinions in which she addressed whether a California corporate franchise tax violates the U.S. Constitution, how states can tax citizens and when employment taxes apply to baseball players’ back pay. Justice Ruth Bader Ginsburg in a panel discussion at Georgetown University Law […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth Individuals

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPA Academy webinar on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth individuals  Thursday, September 29, 2020, 9:00 a.m. – 10:30 a.m. (PST). The Global High Wealth Group is an […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on New Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CPA Academy webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Thursday, September 24, 2020, 2:00 p.m. – 3:00 p.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at […] Read More…

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STEVEN TOSCHER, ROBERT HORWITZ and SANDRA BROWN to Speak on Yes, You Actually Can Go to Jail for Not Paying Taxes

We are pleased to announce that Steven Toscher, Robert Horwitz and Sandra Brown will be speaking at the upcoming CPA Academy webinar on Yes, You Actually Can Go to Jail for Not Paying Taxes, Tuesday, September 22, 2020, 2:00 p.m. to 3:00 p.m. (PST). In recent years, pursuing criminal tax cases involving a taxpayer’s interference […] Read More…

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SANDRA BROWN Quoted in in LAW360 on IRS New Fraud Office

The novel coronavirus pandemic isn’t delaying the rampup of the Internal Revenue Service’s recently launched office to combat tax fraud, the office’s director told Law360 in a recent interview. The former head of the IRS criminal investigation unit is now the director of its new fraud enforcement office. (AP) Though the pandemic has affected the […] Read More…

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