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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives, Tuesday, May 26, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. All tax practitioners need to […] Read More…

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STEVEN TOSCHER quoted in Tax Notes Regarding Recent PPP Prosecutions

Applicants who clearly lied in their applications for the Paycheck Protection Program’s (PPP) tax-free forgivable loans will make better targets for criminal investigation than those who don’t fit lawmakers’ ideas of the program’s intended beneficiaries. “I’m sure there are some blatantly false [statements on PPP loan applications], and I think that is where it’s going […] Read More…

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DENNIS PEREZ, MICHEL STEIN, ROBERT HORWITZ and SANDRA BROWN to speak on What Professionals Need to Know About PPP Loans and Employee Retention Credit

We are pleased to announce that three of our principals Dennis Perez, Michel Stein, Robert Horwitz and Sandra Brown will be speaking at the upcoming CalCPA webinar on What Professionals Need to Know About PPP Loans and Employee Retention Credit, Tuesday, May 19, 2020, 9:00 a.m. – 10:00 a.m. PST. The panel will discuss the tax […] Read More…

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There’s No Getting Around the Pay First, Litigate Later Rule for California Taxes by ROBERT HORWITZ

Most tax professionals are familiar with the Supreme Court’s Flora decision: a taxpayer has to pay in full a tax assessment plus penalties and interest before you can bring a refund suit.  California has had a similar rule, which has been part of the California Constitution since 1913.  Article XIII, sec. 32 of the California […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques, Thursday, June 18, 2020, 1:00 pm-2:30 pm EST, 10:00 am-11:30 am PST. This CLE/CPE webinar will provide […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to speak on Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming CPAacademy webinar on Developments in Cryptocurrency – Reporting and Enforcement, Wednesday, June 3, 2020, 3:00 pm PDT; 2:00 PST. The Internal Revenue Service (IRS) launched a “soft letter” campaign advising taxpayers believed […] Read More…

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STEVEN TOSCHER quoted in Tax Notes on Conservation Easement Tax Enforcement

Enacting a safe harbor for conservation easement valuations may be an ideal way to reconcile Congress’s desire to preserve land with the IRS’s concerns about valuation abuse, according to a practitioner. “In tax law, you can’t help but be involved in valuations,” said Steven Toscher of Hochman Salkin Toscher Perez PC. “But it’s not an exact science, and sometimes it can […] Read More…

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This May Be a Very Good Time to Consider a Voluntary Disclosure By SANDRA R. BROWN

For decades, the Internal Revenue Service (“IRS”) has maintained a voluntary disclosure policy which provides an opportunity for taxpayers to come forward and disclose their noncompliance with the tax laws with the primary incentive being that, in almost all cases, the taxpayer will avoid criminal prosecution. The IRS made some significant announcements recently that could […] Read More…

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Beware Running of Pending Statute of Limitations When Seeking Taxpayer Advocate Service Assistance – IRS Gives Notice of Nonacquiescence with Court of Appeals’ Decision that Found Seeking Help from Taxpayer Advocate Service Tolls Time To File Claim to Challenge Wrongful Levy By SANDRA R. BROWN

The Internal Revenue Service (“IRS”) has recently provided notice that it will, in large part, not follow the adverse decision issued by the Fifth Circuit Court of Appeals in Rothkamm v. United States[i] which found that seeking help from the Taxpayer Advocate Service (“TAS”) tolled the time limits under IRC § 6343(b) for the filing […] Read More…

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EVAN DAVIS to speak on Tax Penalties – What You Must Know

We are pleased to announce that our principal  Evan Davis will be speaking at the upcoming National Business Institute webinar on Tax Penalties – What You Must Know,  Friday, May 15, 2020, 1:00 pm-2:00 pm EST, 10:00 am-11:00 am PST. Protect Yourself and Your Clients The IRS has established more than 150 penalties to ensure […] Read More…

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STEVEN TOSCHER is interviewed on CBS/KNX News Radio in Los Angeles on the IRS successful efforts to get stimulus payments to US taxpayers.

Go to this link and check out minute 25 of the radio segment for Steve’s interview. https://knx1070.radio.com/media/audio-channel/a-potential-breakthrough-for-a-coronavirus-treatment-the-immense-daunting?

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Fifth Circuit Affirms District Court Order Enforcing John Doe Summons Issued to Texas Estate and Tax Planning Firm by Robert S. Horwitz

Eleven months ago I blogged on a district court decision in Taylor Lohmeyer Law Firm P.L.L.C. v. United States, 385 F.Supp. 3d 548 (W.D. TX 2019), enforcing a John Doe summons seeking documents for clients who between 1995 and 2017 used the firm to acquire, establish maintain or control any foreign account, asset or foreign […] Read More…

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