TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 07, 2020

We are pleased to announce that Michel Stein will be speaking at the STEP LA Webinar–Payroll Protection Program Loans: Calculating the Loan Forgiveness Amount, Analysis of Legal Risks of Certifications, Representations in Applicants and Loan Documents, Tax Treatment, SBA Audit Risks, Appeals and Criminal Exposures — on Tuesday, July 14th from 7:30 a.m. – 9:30 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 07, 2020

On the eve of filings lawyers often stay awake at night hoping everything goes right.  Occasionally something goes wrong, you just hope it doesn’t happen to you.  Add one more horror story to the list.  In a harsh result, the Ninth Circuit held that the Tax Court correctly dismissed as untimely Organic Cannabis Foundation’s petition.[1] […] Read More…

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

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the Spidell Webinar–Taxation of Cannabis— on Thursday July 9th  at 10:00 a.m. – 12:00 p.m.  The cannabis business has been growing at very fast pace in California and other jurisdictions since legislative changes legalizing and regulating the sale, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 01, 2020

The moratorium on IRS investigations and collections set forth by the People First Initiative will be ending soon on July 15.[i]  and very high wealth taxpayers should get ready for a little attention from the IRS.  If the moratorium is not extended, the IRS is poised to start the examination of several hundred high net […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 30, 2020

We are pleased to announce that Sandra Brown will be speaking at the ABA Virtual 2020 May Meeting –When You Need to Disclose More Than Just a Tax Crime — on Tuesday July 14th at 2:00 p.m. – 3:00 p.m. (EST). Under the IRS voluntary disclosure practice, in exchange for a timely, accurate, and complete […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 25, 2020

For taxpayers heading into the extended tax season there is good news! The IRS will now allow E-filing of amended returns. The IRS published a notice on May 28, 2020 that amended returns for tax years beginning on or after January 1, 2017 can be filed electronically.[i]  Previously, amended returns had to be submitted manually […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 19, 2020

The Independent Commission for the Reform of International Corporate Taxation (“Commission”) is a group of leaders from around the world who believe that there is both an urgent need and an unprecedent opportunity to bring about significant reform of the international corporate taxation system.  The Commission is comprised of influential members from parliament, the United […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 15, 2020

COVID-19 has placed much of our normal activities on hold.  It hasn’t, however, slowed down the maneuverings around California’s new worker classification law, known as AB5, which took effect January 1, 2020.  Just before the law took effect, the trucking industry won a major victory when Judge Benitez of the Southern District of California issued […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 10, 2020

Comparing recent annual statistics of criminal investigations and  prosecutions by the Internal Revenue Service seems to suggest that the agency may be shifting resources away from criminal tax enforcement. In Fiscal Year 2019, the IRS Criminal Investigation Division initiated 2,485 investigations and recommended 1,893 prosecutions.  This continues a trend seen in recent years of declining […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, June 07, 2020

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPAacademy webinar on Captive Insurance Companies: Where Are We Going After the IRS Victories, Tuesday, June 30 2020, 1:00 pm PST. The Internal Revenue Service (IRS) began sending contact letters in April […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 01, 2020

It’s been so long since I have blogged about FBAR cases I almost forgot they even existed.  This is probably the effect of age.  But decisions in two recent cases show that FBAR willful penalty cases are still alive and reflect that courts are not blindly accepting the Government’s “pushing the envelope” theories.  Both cases […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 01, 2020

Like much of the country, the Tax Court is taking its business online, adopting procedures for remote proceedings on May 29 by issuing Administrative Order No. 2020-02.  Since March 11, when the Tax Court started cancelling trial sessions, court business has virtually stopped.  The Tax Court building in Washington, D.C. itself has been closed since […] Read More…