TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, April 11, 2021

What does the title of one of Sergio Leone’s great Clint Eastwood westerns have to do with Foreign Bank Account Reports (known in the trade as “FBARS”) and FBAR penalties.  Two significant court of appeal opinions and a district court opinion involving the FBAR penalty were issued recently (United States v. Boyd, __ F.3d __, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, April 10, 2021

“When a man’s got money in his pocket he begins to appreciate peace.” The Man With No Name Why start with a quote from one of Sergio Leone’s great Clint Eastwood westerns, A Fistful of Dollars.   It is more peaceful to have money in your pocket, or at least close by in a domestic financial […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, April 10, 2021

In the Lord of the Rings saga, the antagonist is a disembodied entity called Sauron who was represented by a flame-filled “Great Eye.”  Sauron’s Great Eye had powerful vision when fixed upon his rivals, but even this powerful eye was unable to see unaided into the thoughts of humans.  Fans of the LOTR movies know […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, April 01, 2021

On March 30, the Department of Justice, Tax Division, filed a petition for leave to serve a “John Doe” summons on Payward Ventures, also known as “Kraken,” requesting account information for all United States taxpayers who held accounts there with the equivalent value of $20,000 or more in cryptocurrency for any one year from 2016 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 31, 2021

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Strafford webinar, “Cryptocurrency Tax Compliance in the Post-$50,000 Bitcoin World: Tax Filing Requirements, Managing IRS Examinations” on Thursday, April 22, 2021, 10:00 a.m. – 11:30 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST).  This CLE/CPE webinar […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 22, 2021

We are very pleased to announce that Sandra Brown is featured in  this month’s  Los Angeles Lawyer discussing the IRS Voluntary Disclosure Practice. Check out the current state of the practice and Sandra’s insights. The tax system of the United States is often described as one of “voluntary compliance.”  However, there is little about the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 21, 2021

The Internal Revenue Service will continue its focus on collecting delinquent taxes from the wealthiest taxpayers. The Treasury Inspector General for Tax Administration (TIGTA) recently published a report on the IRS efforts to collect delinquent taxes from wealthy taxpayers. This is the second report by  TIGTA on the IRS attempts to increase compliance of this […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 21, 2021

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Spidell webinar, “Handling Partnership Examinations” on Thursday, March 25, 2021, 10:00 a.m. – 12:00 p.m. (PST). This webinar will cover practical considerations for partners and advisers to partnerships now operating under the new partnership audit regime. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 10, 2021

“Friend of the JTPP, Robert S. Horowitz shares an update on penalties in The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes. It’s good to hear the phrase “non-willful FBAR cases” even if it is a rare case. It seemed for a while that IRS wasn’t able to find […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 10, 2021

The IRS Criminal Investigation division isn’t focusing its enforcement efforts specifically on cannabis businesses, but is instead treating them like any other cash-intensive business, according to a division official. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes in part that “. . . practitioners with cannabis clients might need to keep a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 09, 2021

Steven Toscher recently had the opportunity to moderate a Federal Bar Association panel on the IRS new Office of Fraud Enforcement. While much attention was paid on the panel  to the  unveiling some of IRS Crown Jewels  by the new OFE Director Damon Rowe and it’s “Operation Hidden Jewels” in its cryptocurrency enforcement efforts, Steve […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 05, 2021

The price of Bitcoin rose dramatically in 2020 and even doubled in price since the beginning of 2021. On January 1, 2021, Bitcoin was $29,336.31 and on February 21, 2021, it was $58,012.09. Many who have sold their Bitcoin have made a profit. Where there’s profit, there’s income – and where there’s income, there’s tax.  […] Read More…