TAXLITIGATOR Blog

MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak on BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successor Liability, and More

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successor Liability, and More” on Tuesday, December 1, 2020, 10:00 a.m. – 11:30 a.m. (PST). The IRS Large Business and International Division stated […] Read More…

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SANDRA BROWN to Speak on The Consequences of Conviction: The U.S. Sentencing Guidelines, Restitution, Forfeiture, and Collateral Consequences

We are pleased to announce that Sandra Brown along with Jeffrey Sklarz of Green & Sklarz, Frank Agostino of Agostino & Associates and Christine Sciarrino, Department of Justice will be speaking at the upcoming IRS Representation Conference live webcast, “The Consequences of Conviction: The U.S. Sentencing Guidelines, Restitution, Forfeiture, and Collateral Consequences” on Thursday, November […] Read More…

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ROBERT HORWITZ to Speak on Problems Facing Taxpayers with Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)

We are pleased to announce that Robert Horwitz along with Megan Brackney of Kostelanetz & Fink and Patrick Martin of Procopio will be speaking at the upcoming USD School of Law/Procopio International Tax Institute virtual webinar, “Problems Facing Taxpayers with Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)” on Thursday, November 12, […] Read More…

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STEVEN TOSCHER, DENNIS PEREZ and MICHEL STEIN to Speak on Federal and California Tax Update for Individuals

We are pleased to announce that Steven Toscher, Dennis Perez and Michel Stein will be speaking at the upcoming CalCPA webinar, “Federal and California Tax Update for Individuals” on Thursday, November 5, 2020, 2:00 p.m. – 3:00 p.m. (PST). Steve, Dennis and Michel will be speaking on important practice and procedural issues facing practitioners, including IRS priorities and the new […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and LACEY STRACHAN to Speak on The Life of an Estate Tax Case: Tips and Strategies for Audit, Appeal, and Tax Court

We are pleased to announce that Steven Toscher, Michel Stein and Lacey Strachan will be speaking at an upcoming Spidell webinar, “The Life of an Estate Tax Case: Tips and Strategies for Audit, Appeal, and Tax Court” on Friday, October 30, 2020, 10:00 a.m. – 12:00 p.m. PST Practical advice for preparing for and resolving estate tax […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak on IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals and Litigation

We are pleased to announce that Steven Toscher, Michel Stein and Lacey Strachan will be speaking at an upcoming Spidell webinar, “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals and Litigation” on Thursday, November 5, 2020, 10:00 a.m. – 12:00 p.m. PST/1:00 p.m. – 2:50 p.m. EST This webinar will review the IRS’ latest […] Read More…

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SANDRA BROWN to Speak on From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update

We are pleased to announce that Sandra Brown along with Mark Allison, Larry Campagna, Guinevere Moore and Carolyn Schenck will be speaking at the upcoming NYU 79th Virtual Institute on Federal Taxation webinar, “From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update” on Monday, November 16, 2020, 1:30 p.m. – 4:30 […] Read More…

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UCLA 36th Annual Tax Controversy Virtual Institute -October 20, 2020

Please join Michel Stein as he moderates a panel: LB&I’s New High Wealth Examinations-Is there Really Gold in Them Hills along with Holly Paz, IRS Director of Pass-Through Entities, LG&I, Michael Cohen, DeCastro West, Chodorow and Philip Wilson, Marcum, LLP. The program’s learning objectives include: Learn about the Global High Wealth Group audit program Better Understand the Global High Wealth Group examination […] Read More…

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UCLA 36th Annual Tax Controversy Virtual Institute -October 20, 2020

Please join Sandra R. Brown, former Acting United States Attorney, as she moderates a panel featuring IRS Director of Fraud Enforcement Damon Rowe and IRS CI Special Agent in Charge Ryan Korner, entitled “What Every Practitioner Needs to Know to Protect Their Clients and Themselves From Civil Fraud Penalties and Criminal Investigations”, to be webcast […] Read More…

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STEVEN TOSCHER, DENNIS PEREZ and CORY STIGILE to Speak on High Net Worth Audits

We are pleased to announce that Steven Toscher, Dennis Perez, and Cory Stigile will be speaking at an upcoming Spidell webinar, “High Net Worth Audits” on Wednesday, October 21, 2020, 10:00 a.m. – 12:00 p.m. PST The Global High Wealth Group is an industry group created by the IRS LB&I in 2009. The purpose of the Global […] Read More…

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STEVEN TOSCHER DENNIS PEREZ and MICHEL STEIN to Speak on High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance

We are pleased to announce that Steven Toscher, Dennis Perez and Michel Stein will be speaking at an upcoming Strafford webinar, “High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance” on Thursday, October 22, 2020, 1:00 p.m. – 2:30 p.m. EDT/ 10:00 a.m. – 11:30 a.m. PST The IRS has increased […] Read More…

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What Makes a Failure to File Your Tax Returns a Felony? by SANDRA BROWN

As Benjamin Franklin once wrote, “in this world nothing can be said to be certain, except death and taxes.” For any U.S. citizen or resident with annual income in excess of a statutorily determined amount, the requirement to file a tax return is not only certain, but is a legal obligation. Contrary to popular myth, […] Read More…

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