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SANDRA BROWN Quoted in Law 360 on Tax Opinions by Justice Stevens

SANDRA BROWN quoted in Law 360 article, “5 Fascinating Tax Opinions By Justice Stevens” on U.S. v Caceres case. To view full article with Sandra’s comments Click Here.

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Los Angeles Lawyer -The Impact of “Big Data” on IRS Civil and Criminal Tax Enforcement by STEVEN TOSCHER and DANIEL KELLERMAN

Much has been written over the last year concerning the lack of funding for the  Internal Revenue Service and what it means for tax enforcement.  It is well established that for every dollar spent on tax enforcement, at least four dollars are brought into the U.S. Treasury.  This makes a very compelling case for spending more—not less—on tax enforcement, […] Read More…

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AVRAM SALKIN and MICHEL STEIN to teach at upcoming PINCUS PROFESSIONAL EDUCATION Exam Prep for Tax Law Certified Specialist

We are pleased to announce that Avram Salkin and Michel Stein will be teaching at the upcoming exam preparation for the Tax Law Certified Legal Specialist Exam, August 22-23, 2019 at the Doubletree Hotel, Downtown Los Angeles. Avram Salkin will teach on August 22nd on Real Estate Taxation from 3:40 p.m. – 4:30 p.m. and Estate, Gift and Fiduciary Income Tax from […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Tax Reporting of Cryptocurrency: Calculating Basis, Income and Gain

We are pleased to announce that Steven Toscher and Michel Stein will be presenting at an upcoming STRAFFORD WEBINAR: Tax Reporting of Cryptocurrency: Calculating Basis, Income and Gain.  Thursday, August 29, 2019 from 10:00 a.m. – 11:50 p.m. (PST)/1:00 p.m. to 2:50 p.m. (EDT).  For more information Click Here. This webinar will provide tax advisers […] Read More…

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JONATHAN KALINSKI to speak on Anatomy of a Tax Court Case: Litigation Tips from an Expert – July 18, 2019

We are pleased to announce that Jonathan Kalinski will be presenting at an upcoming myLawCLE /FEDERAL BAR ASSOCIATION WEBINAR: Anatomy of a Tax Court Case: Litigation Tips from an Expert  Thursday, July 18, 2019 from 4:00 p.m. – 6:00 p.m. Eastern | 3:00 p.m. – 5:00 p.m. Central | 2:00 p.m. – 4:00 p.m. Mountain […] Read More…

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BRUCE I. HOCHMAN AWARD FOR EXCELLENCE IN THE STUDY OF TAX LAW Awarded to NATHAN COX

BRUCE I. HOCHMAN AWARD FOR EXCELLENCE IN THE STUDY OF TAX LAW Awarded to NATHAN COX

We are pleased to announce the 2019 Bruce I. Hochman Award for Excellence in the Study of Tax Law was awarded to graduating UCLA Law student Nathan Cox.  The award honors the significant legacy of UCLA Law alumnus Bruce Hochman by recognizing the most outstanding graduating tax student at the law school each year.  Granted annually since its creation […] Read More…

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STEVEN TOSCHER and SANDRA BROWN to speak at upcoming Fourth Annual USD RJS Law Tax Controversy Institute, July 19, 2019

We are pleased to announce that two of our principals, Steven Toscher and Sandra Brown, the former Chief Tax prosecutor in the Central District of California, will be speaking at the upcoming 4th Annual USD School of Law RJS Law Tax Controversy Institute at University of San Diego, Joan B. Kroc Institute for Peace and […] Read More…

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SANDRA BROWN Quoted in Tax Analysts Article on IRS Data Analytics

SANDRA BROWN quoted in Tax Analysts’ article, “IRS Data Analytics Could Start Race on Voluntary Disclosures.” Sandra said the new data sets and analytics tools are allowing the IRS to make connections on its own in situations in which it used to rely on informants and use those connections to open civil and criminal investigations. […] Read More…

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Tax Notes -The Outer Bounds of Discretionary Sentencing in Criminal Tax Cases by STEVEN TOSCHER

In this article, Toscher examines the judicial evolution of sentencing in federal tax cases under the non-mandatory guidelines. Before the promulgation of the federal sentencing guidelines effective November 1, 1987, the sentence of an individual convicted of a federal tax crime was discretionary with the trial court. That changed with the federal sentencing guidelines because of the concerns for […] Read More…

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STEVEN TOSCHER and MICHEL STEIN Quoted in Law360 Article on Upcoming Cryptocurrency Guidance From IRS

STEVEN TOSCHER and MICHEL STEIN are quoted in Law360’s article, “Expect IRS Crypto Guidance On Basis, Hard Forks, Attys Say. Highly anticipated IRS guidance on cryptocurrency will likely address cost basis and the treatment of hard forks, or the splitting of cryptocurrency blockchain, and will likely be more authoritative than guidance put out in 2014, […] Read More…

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IRS to Strengthen Its Taxpayer Fraud Referral Procedures by STEVEN TOSCHER

The Treasury Inspector General for Tax Administration Issued a report to the IRS Commissioner on  May 23, 2019 pointing the way to increasing the efficacy of its Information Referral  Program to increase tax compliance and raise revenue. The IRS has long had a program where the public could report to the IRS alleged non-compliance with […] Read More…

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11th Circuit Holds that “My Boss Told Me Not to Pay” Is Not a Defense to Trust Fund Penalties, Even Where the Boss Is a Government Agency by LACEY STRACHAN

The general rule is that under IRC Section 6672(a), a person “required to collect, truthfully account for, and pay over any tax…who willfully fails to collect such tax, or truthfully account for and pay over such tax” (known as trust fund taxes) is liable for a penalty equal to the total amount of the tax […] Read More…

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