TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 18, 2020

You could be forgiven for thinking that law enforcement officers have to identify the location to be searched accurately when asking a judge to sign a search warrant.  The Fifth Circuit decided on March 4, 2020, that missing the address by ½ and not even describing the actual premises to be searched, aren’t big enough […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 10, 2020

Section 1501 of the Internal Revenue Code allows a parent corporation and its subsidiaries to file a consolidated return that effectively treats the consolidated group as one entity for tax purposes.  The IRS has issued detailed regulations concerning consolidated groups.  It has not issued any regulations on how refunds to a consolidated group are to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 08, 2020

The Internal Revenue Service (“IRS”)  took a major step in enhancing its criminal fraud referral program by announcing a national coordinator who will oversee fraud referrals from all of the operating divisions.  Damon Rowe, formally the Executive Director of International Operations for IRS Criminal Investigations and former Special Agent in Charge of the Los Angeles […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 01, 2020

We are pleased to announce that three of our principals Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Adviser, Tuesday, March 31, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The IRS is forceful in its efforts to pursue taxpayers […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 01, 2020

We are pleased to announce that three of our principals Michel Stein, Robert Horwitz, and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Partnership Audit Adjustments Under the Centralized Audit Regime, Wednesday, April 22, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The centralized partnership audit regime (CAR) is effective now. The Bipartisan Budget […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, February 22, 2020

I recently blogged on the Eleventh Circuit’s decision in In re Shek rejecting First, Fifth and Tenth Circuit precedent that a late return filed two years or more before bankruptcy is not discharged.  Today I am blogging on another recent bankruptcy case, In re Harold, 2020 WL 709866 (B. Ct. M.D. Mich. 2/12/2020), which addressed […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, February 22, 2020

On February 19, 2020, the IRS issued IR-2020-34, which states the IRS “will step up efforts to visit high-income taxpayers who in prior years have failed to timely file one or more of their tax returns.”  If the Commissioner of Internal Revenue Charles P. Rettig was speaking, he might say that high income taxpayers who […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 19, 2020

Three types of tax debts are excepted from discharge in bankruptcy: First, those entitled to priority under sec. 507(a) of the Bankruptcy Code.  11 U.S.C. Sec. 523(a)(1)(A). Second, those with respect to which a return, if required, was not filed or was filed after it was last due and after two years before the date […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 13, 2020

We are pleased to announce that Michel Stein will be speaking at the upcoming SFVBA Taxation Law Section Seminar on Update on the Taxation of Cryptocurrency Transactions, Tuesday, February 18, 2020, 12:00 pm-1:15 pm. Mr. Stein will discuss new IRS pronouncement and recent developments regarding taxation of cryptocurrency transaction For full programming details Click Here.   […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 10, 2020

We are pleased to announce that Michel Stein has been elected as Fellow by the American College of Tax Counsel. Michel, a principal of our firm, joined us in 1998, after a prestigious position as an Attorney-Advisor at the United States Tax Court. He holds an LL.M in Taxation from New York University and is a former Chair […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, February 09, 2020

In 2018, Robert Horwitz posted a blog on the Appeal of Mitchell (8/2/2018), a favorable Office of Tax Appeals Opinion (the “Opinion”) that approved a “drop and swap” transaction. The FTB filed a Petition for Rehearing, which has been pending until last week when a majority Opinion on Petition for Rehearing concluded that the FTB […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 06, 2020

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 Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual and Business Taxpayers, Tuesday, February 11, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals […] Read More…