TAXLITIGATOR Blog

DENNIS PEREZ, SANDRA BROWN and CORY STIGILE to Speak at Upcoming Spidell Webinar

We are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming Spidell webinar “Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses,” Thursday, September 29, 2022, 10:00 a.m. – 12:00 p.m. (PST). Research and development (R&D) is the lifeblood of a growing and prosperous economy, and many […] Read More…

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STEVEN TOSCHER to Speak at Upcoming CSTC Webinar

We are pleased to announce that Steven Toscher will be speaking at the upcoming CSTC 2022 Tax Forum Orange County South Chapter seminar at The Hills Hotel, Laguna Hills on “Cryptocurrency Tax Compliance: Tax Filing Requirements; Managing IRS Examinations,” Friday, September 16, 2022, 1:00 p.m. – 2:50 p.m. (PST). This course will provide tax counsel, accountants, and other advisers with a critical […] Read More…

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First Circuit in a Cryptocurrency Summons Enforcement Case Widens the Crack Created in the Anti-Injunction Act by CIC Services, LLC, v IRS
By Sandra R. Brown
[i] and Gary Markarian[ii]

Introduction It was a long-held belief that the Anti-Injunction Act barred Taxpayers from maintaining any lawsuit that had the effect of interfering with the assessment or collection of any tax. However, the recent Supreme Court decision in CIC Services created a crack in the Government’s use of the Anti-Injunction Act to dismiss cases for lack […] Read More…

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PHILIPP BEHRENDT to Speak at Upcoming Beverly Hills Bar Webinar

We are pleased to announce that Philipp Behrendt, along with LaVonne Lawson, Richard Gano and Michele F.L. Weiss will be speaking at the upcoming webinar at the Beverly Hills Bar Association on “Tax Impacts of the Inflation Reduction Act,” Tuesday, August 30, 2022, 12:30 p.m. – 1:30 p.m. (PST). President Biden recently signed The Inflation Reduction Act into law. The Act contains numerous tax provisions. […] Read More…

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Treece Financial Services Group v. Commissioner – The Broad Sweep of Tax Court Jurisdiction By: STEVEN TOSCHER, MICHEL STEIN and PHILIPP BEHRENDT

The Tax Court’s jurisdiction has been expanding over the years, both by legislation and rulings designed to make sure that taxpayers have adequate remedies.. This is the message in Treece Financial Services Group v. Commissioner, 158 T.C. No. 6, as well as the related opinion Treece Investment Advisory Corp. v. Comm’r, T.C. Memo 2022-38 (both […] Read More…

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SANDRA BROWN to Speak at Upcoming 39th Symposium on Economic Crime

We are pleased to announce that Sandra R. Brown will be speaking on upcoming seminars at the 39th Symposium on Economic Crime – Jesus College, University of Cambridge, being held at Jesus College, a College within the University of Cambridge, Sept. 4–11, 2022. Sandra will be participating on a panel entitled “Getting Your House in Order – Conducting Internal Investigation Into […] Read More…

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MICHEL STEIN to Speak at Upcoming CPA Academy Webinar

We are pleased to announce that Michel Stein along with Phillip Colasanto, Caroline Ciraolo and Daniel Price, will be speaking at the upcoming CPA Academy on “Coming in From the Cold: the Future of Voluntary Disclosures” on Tuesday, August 23, 2022, 2:00 p.m. – 3:00 p.m. (PST). For more than 70 years, the IRS maintained a voluntary disclosure policy designed to encourage […] Read More…

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STEVEN TOSCHER to Speak at Upcoming ABA Webinar

We are pleased to announce that Steven Toscher along with Sara Neill, Peter Poulos and Charles Wien will be speaking at the upcoming ABA “Reportable Transactions for Estate Planners” on Tuesday, August 30, 2022, 10:00 a.m. – 11:30 a.m. (PST). Click Here to Register This esteemed panel of tax professionals will address reportable transactions for estate planners. Panelists will identify […] Read More…

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Chambers USA 2022 Recognizes Hochman Salkin Toscher Perez P.C.

HOCHMAN SALKIN TOSCHER PEREZ P.C. is proud to be recognized by Chambers and Partners as one of only three top tier law firms in its U.S. 2022 High Net Worth Guide in the category of Tax: Private Client. High Net Worth Guide Rankings Chambers states that HOCHMAN SALKIN TOSCHER PEREZ P.C., is “a superb firm […] Read More…

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Tax Evasion Has Its Consequences -The Removal Order by SANDRA BROWN, STEVEN TOSCHER and PHILIPP BEHRENDT

For non-U.S. citizens, criminal convictions can have broader reaching consequences, in addition to the already severe criminal and civil penalties. A felony tax evasion conviction in which the revenue loss to the government exceeds $10,000, or even an attempt or conspiracy to evade with over $10,000 in intended losses, is expressly mentioned in the Immigration […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming Strafford Webinar

We are pleased to announce that Steven Toscher, Michel Stein along with Thomas Giordano will be speaking at the upcoming Strafford webinar, “IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process” on Thursday, August 11, 2022, 10:00 a.m. – 11:30 a.m. (PST). The IRS has and continues to audit a higher proportion of ex-pat tax […] Read More…

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STEVEN TOSCHER Quoted in Tax Notes on IRS Voluntary Disclosure Guide Reveals New Details of Practice

A recently acquired IRS guide for voluntary disclosure practice (VDP) examiners provides insights into the IRS’s actions and priorities within the practice and could give practitioners more confidence and familiarity with it. Steven Toscher weighs in and states cooperation has always been an essential condition of the practice, though that is not to say that […] Read More…

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