TAXLITIGATOR Blog

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 03, 2020

We are pleased to announce that Steven Toscher, will be speaking along with Sarah E. Paul, Eversheds Sutherland, Niles Elber, Caplin & Drysdale, Thomas Curteman, Jr., Office of Chief Counsel, IRS and Hank Kea, Field Collection Operations, IRS on “Avoiding or Not Avoiding Evasion of Payment Prosecutions & the Civil Aftermath” at this year’s Federal […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 30, 2020

We are pleased to announce that Sandra Brown, will be moderating the panel  along with Jason B. Freeman, Freeman Law, Victor Jaramillo, Caplin & Drysdale, and  John Siddons, Supervisory Special Agent, Internal Revenue Service, Criminal Investigation on “A Client with Cryptocurrency Just Call – What Now?” at this year’s ABA Midyear Tax Meeting, Saturday, February […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 27, 2020

We are pleased to announce that two of our principals Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers, March 31, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals and advisers on critical issues relating […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 20, 2020

Enforcement and compliance is a top priority of the Internal Revenue Service (“IRS”). The IRS has 150 penalties at its disposal to assist in its stated goals of enforcement and obtaining compliance with the tax laws of the United States. Many of these penalties can be assessed not only against taxpayers but also against tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, January 08, 2020

We are pleased to announce that three of our principals will be speaking at the upcoming Strafford webinar on New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops, January 14, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will discuss recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding taxation of cryptocurrency. With […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 06, 2020

SANDRA BROWN quoted in Tax Analysts’ article, “Ride Across the Marinello Bridge Cases Could Be Bumpy.” Sandra R. Brown of Hochman Salkin Toscher Perez PC compared the bridge-case transition with the change in behavior that followed Booker v. United States, 514 U.S. 220 (2005) — the case in which the Supreme Court declared that the sentencing guidelines […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, December 20, 2019

On December 2, 2019, the Internal Revenue Service released Rev. Proc. 2019-42, which applies to any income tax return filed on 2019 tax forms for the 2019 tax year, including 2019 tax forms for short taxable years beginning in 2020 if filed before the forms for 2020 are available.  This updated revenue procedure, which updates […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 18, 2019

the new Taxpayer First Act, among other benefits will bring the IRS into the twenty-first century. It has been more than 20 years since the U.S. Congress addressed taxpayer rights in the Tax Reform and Restructuring Act of 1998.1 In June 2019, H.R. 3151, otherwise known as the Tax payer First Act, was introduced in […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 16, 2019

Gary Markarian is a recent graduate of Loyola Law School’s joint J.D./ Tax LL.M. program, where he graduated with High Distinction. Prior to law school, he graduated from the University of California, Los Angeles, with a B.A. in Political Science. Gary’s prior experience includes working as a law clerk for the Law Offices of Givner & […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 11, 2019

Please join us January 27-29, 2020 for the USC Gould School of Law 2020 Tax Institute at the Millennium Biltmore Hotel, Los Angeles. Learn the latest tax law developments for corporations, privately-held businesses, individuals, partnerships and real estate transactions, and important tax ethics, compliance, enforcement and estate planning solutions. Take away practical tips from over 75 veteran tax professionals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 02, 2019

The IRS recently has become more aggressive in assessing foreign information reporting penalties against taxpayers who fail to file required forms for foreign trusts or who file them late.  For years, we have been writing about the IRS’ enforcement efforts with respect to offshore accounts and assets.   With what has generally been perceived as successfully […] Read More…