TAXLITIGATOR Blog

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

We are pleased to announce that Steven Toscher and Michel Stein will be presenting at an upcoming STRAFFORD WEBINAR: Tax Treatment of Cryptocurrency Losses Suffered by Individual Taxpayers.  Thursday, September 12, 2019 from 10:00 a.m. – 11:50 p.m. (PST)/1:00 p.m. to 2:50 p.m. (EDT).  For more information Click Here. Investments in bitcoin and other cryptocurrencies […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 21, 2019

IRS Commissioner Charles Rettig’s commitment to fighting tax fraud seems to have manifesteditself in at least one of his recent personnel moves. Starting September 1, the deputy chief of the Criminal Investigation division, Eric Hylton, will take over as commissioner of the Small Business/Self-Employed Division, and a couple days later, Darren Guillot will move from director of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 16, 2019

Practitioners are disturbed by a possible legal stance of the Justice Department in the latest dust-up over foreign bank account reporting, which would negate reliance on a professional as a defense to willful penalties. Tax Notes talked with two practitioners following filings of a joint pretrial statement and proposed jury instructions in Dadurian that seemingly […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 16, 2019

The IRS has recently provided interim guidance to clarify actions IRS Examiners musttake to analyze and document Currency Transaction Report (CTR) data during an audit.  The Guidance, which is effective immediately, will be incorporated into IRM 4.10.4, Examination of Returns, Examinations of Income. Prior to incorporation, IRM 4.10.4 provided very little guidance on when and how to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 13, 2019

We are pleased to announce that Sandra R. Brown, along with Chair Ian Comisky, Fox Rothschild and Panelists Don Fort, Chief, Criminal Investigation IRS, Larry Campagna, Chamberlain Hrdlicka, and Caroline Ciraolo, Kostelanetz & Fink, will be speaking on “Cooperation or Compulsion: The Emerging U.S. Experience with Voluntary and Involuntary Disclosures of Foreign Transactions,” at the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 02, 2019

We are pleased to announce that Sandra Brown will be presenting at an upcoming ABA WEBINAR: The Rise of Injunction and Disgorgement Actions under Section 7402 of the Internal Revenue Code.  Thursday, August 15, 2019, 1:00 p.m. EDT/ 10:00 a.m. PST.  For more information Click Here. This webinar explores the current legal and enforcement landscape surrounding […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 30, 2019

For those who have failed to report their cryptocurrency transactions correctly — be warned.   The Internal Revenue Service (IRS) is paying attention. IRS Virtual Currency Contact Letters Beginning this month (July 2019), the IRS has begun sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay tax from virtual […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 23, 2019

IRS CI wants more fraud referrals – from the IRS Operating Divisions. The value of the IRS’s ongoing voluntary disclosure program, both to non-compliant taxpayers and the IRS, for the goals of obtaining and encouraging tax compliance is without question.  On July 19th, Don Fort, Chief of IRS Criminal Investigation, while speaking at the University […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 23, 2019

An attorney has many duties, including a duty of candor as well as a duty to maintain a client’s confidences, when representing a client before the IRS. On July 19th, speakers and audience members attending the University of San Diego School of Law and RJS Law Tax Controversy Institute in San Diego raised many points […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 23, 2019

Internal Revenue Code § 6694 imposes a penalty on return preparers who understate a taxpayer’s tax liability.  The amount of the penalty is $1,000 per return if the understatement is due to an “unreasonable” position.  § 6694(a)(1).  Under § 6694(b)(1), the amount is the greater of $5,000 or 75% of the income derived by the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, July 21, 2019

Internal Revenue Service Criminal Investigation Division’s Los Angeles Field Office’s 100 year anniversary celebration was held on Thursday night at The Federal Bar in Long Beach. There was a huge turnout of both active and retired agents.  I was thrilled to join in the celebration, along with my partners Steve Toscher, Robert Horowitz and Cory […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 19, 2019

SANDRA BROWN quoted in Law 360 article, “5 Fascinating Tax Opinions By Justice Stevens” on U.S. v Caceres case. To view full article with Sandra’s comments Click Here.