TAXLITIGATOR Blog
A Discussion of Learning Resources, Inc., in which the Supreme Court Struck Down the President’s Claim to Impose Tariffs at Will by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Tuesday, March 03, 2026
You undoubtedly know by now that on Friday, February 20, 2026, the United States Supreme Court held that Pres. Trump does not have the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs on imports. Not one to be deterred, Pres. Trump immediately announced the imposition of a 10% global tariff under […] Read More…
Read MoreMichel R. Stein and Cory Stigile to Speak at Upcoming Barbri Webinar on Navigating IRS Corporate and High-Income Taxpayer Audits
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 02, 2026
We are pleased to announce that Michel R. Stein and Cory Stigile along with Timothy Bilotta will be speaking at the upcoming Barbri webinar on Navigating IRS Corporate and High-Income Taxpayer Audits, on Wednesday, March 4, 2026, 10:00 a.m. – 11:30 a.m. (PST). We are honored to have Tim join us for the program. Tim is recently retired from […] Read More…
Read MoreSebastian Voth to Speak at Upcoming Barbri Webinar on the Economic Substance Doctrine: Withstanding IRS Challenges
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 25, 2026
We’re pleased to announce that Sebastian Voth along with Ed Froelich and Sam Hamer (McDermott, Will & Schulte) will be speaking at the upcoming Barbri webinar on Economic Substance Doctrine: Withstanding IRS Challenges on Thursday, March 5, 2026, 10:00 a.m. – 11:50 a.m. (PST). This webinar will review the economic substance doctrine (“ESD”) as it has […] Read More…
Read MoreSteven Toscher to Speak at Upcoming UCLA School of Law and Loyola School of Law 29th Annual Western Conference on Tax Exempt Organizations
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 23, 2026
We are pleased to announce that Steven Toscher will be speaking at the UCLA School of Law Lowell Milken Center for Philanthropy and Nonprofits and Loyola Law School 29th Annual Western Conference -Tax Exempt Organizations on Audits and Investigations, Friday, March 13,2026, 11:15 a.m. – 12:30 p.m. the California Endowment’s Center for Healthy Communities in Downtown […] Read More…
Read MoreThe California Office of Tax Appeals Hands Taxpayers a Partial Victory in a Like-Kind Exchange Case by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 20, 2026
Sec. 1031(a) of the Internal Revenue Code provides that no gain or loss is recognized when property held for productive use in a trade or business or for investment is exchanged for like-kind property to be held either for productive use in a trade or business or for investment. The purpose of section 1031 is […] Read More…
Read MoreThe California Supreme Court Says the Only Way to Challenge a Special Assessment of Property Tax is by Exhausting Administrative Remedies by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 18, 2026
In 2008, California enacted the Property Assessed Clean Energy (“PACE”) Act that allows local governments to provide homeowners with financing for energy efficient home improvements. PACE allows local governments to fund their PACE programs by issuing bonds. The special assessment is assessed and collected “in the same manner and at the same time” as local […] Read More…
Read MoreSteven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 13, 2026
On my way to Mérida in the Yucatán. Great weather, great food, Mayan ruins and exploration of the intersection of tax fraud and customs fraud with two great panel members, Wazirah Allen, IRS-Criminal Investigations, Director of International Operations and Jeff Neiman, Neiman Mays Floch & Almeida PLLC. Patrick Martin is a great host and thank you University of SanDiego […] Read More…
Read MoreThe California Supreme Court Says the Only Way to Challenge a Special Assessment of Property Tax is by Exhausting Administrative Remedies by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 05, 2026
In 2008, California enacted the Property Assessed Clean Energy (“PACE”) Act that allows local governments to provide homeowners with financing for energy efficient home improvements. PACE allows local governments to fund their PACE programs by issuing bonds. The special assessment is assessed and collected “in the same manner and at the same time” as local […] Read More…
Read MoreSteven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 03, 2026
We are pleased to announce that Steven Toscher along with Wazirah Allen, IRS-Criminal Investigations, Director of International Operations and Jeffrey Neiman will be speaking at the upcoming University of San Diego School of Law – Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind, February 16-17,2026, at Centro Internacional de […] Read More…
Read MoreSebastian Voth and Philipp Behrendt to Teach through UCLA Extension on Digital Assets Taxation
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 02, 2026
We’re pleased to announce that Sebastian Voth and Philipp Behrendt will be teaching this online course on Taxation of Digital Assets offered by UCLA Extension from February 10th through March 17th. This online course prepares legal and tax professionals to plan, analyze, and implement compliant reporting for digital-asset transactions under current IRS rules. We concentrate on statutory and regulatory […] Read More…
Read MoreFifth Circuit Hands the Taxpayer a Win in the First Appeals Court Case Interpreting “Limited Partner” for Purposes of Self-Employment Tax by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 30, 2026
Social security and Medicare tax is based on wages paid employees under Internal Revenue Code (IRC) § 3101 and “net earnings from self-employment” under IRC § 1401. “Net earnings from self-employment” is defined in IRC § 1402 and includes an individual partner’s “distributive share … of income or loss” of the partnership. Section 1402 contains […] Read More…
Read MoreFrom the Los Angeles Garment District to the Southwest Border to the Most Populous County in Minnesota – How the Treasury Department’s Issuance of Geographic Targeting Orders “Follow the Cash” to Combat Financial Crimes by Sandra R. Brown
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, January 28, 2026
On January 8, 2026, in response to alleged benefits fraud in Minnesota, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced the issuance of a Geographic Targeting Order (GTO) requiring all banks and money transmitters located in Hennepin County and Ramsey County, Minnesota, (Covered Businesses) to file reports with FinCEN of certain international fund transfers […] Read More…
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