TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, October 25, 2018

Pro se petitioners James and Tina Loveland hit a home run in a CDP case that resulted in a formal Tax Court opinion, Loveland v. Commissioner, 151 T.C. No. 7 (September 25, 2018), here.  The Tax Court has three levels of opinions: 1) a formal Tax Court opinion, which is published in the Tax Court Reporter and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, October 25, 2018

DEDUCTIBILITY AND INFORMATION REPORTING OF RESTITUTION PAYMENTS: TRANSITIONAL GUIDANCE ISSUED The Tax Cuts & Jobs Act made significant changes to Section 162(f) with respect to the deductibility of certain fines, penalties, and other amounts, including restitution payments. Previously, Section 162(f) barred a deduction for fines or penalties paid to a government for the violation of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, October 21, 2018

Plan on joining us on October 23rd to help celebrate the 34th anniversary for one of the preeminent conferences exclusively dedicated to tax controversy and tax litigation. The Annual Tax Controversy Institute provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience. MESSAGE […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, September 23, 2018

The length of time you should keep a document depends on the action, expense, or event which the document records. Generally, you must keep your records that support an item of income, deduction or credit shown on your tax return until the period of limitations for that tax return runs out. For most taxpayers, the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 03, 2018

Steven Toscher, Esq. and Michel Stein, Esq speaks with Eric Green, Esq.of the Tax Rep Network about everything you need to know about Cryptocurrency: What it is, how the IRS views cryptocurrency, how to report these transactions, can you do a like-kind exchange of cryptocurrency, why it’s such a hot button issue with the IRS […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, September 01, 2018

We are pleased to announce that Evan Davis will be speaking at an upcoming Knowledge Group live webinar The Nuts and Bolts of Tax Penalties: A Practical Guide scheduled for Friday, September 21, 2018 from 12:30 p.m. to 2:00 p.m. Eastern Time. As the number of tax evasion or tax fraud cases continues to rise, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 30, 2018

The program is the first in a series of programs covering important topics in Federal Criminal Tax Enforcement and Litigation – including a post-mortem on the Manafort case. How Criminal Tax Cases Originate. Avoiding a Criminal referral from the Civil Examination or Collection Division of the IRS. The Administrative Conference Process—Unique to Tax Cases. Pre-Indictment […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, August 18, 2018

2018 TNT 159-3 ROTATING FRAUD TECHNICAL ADVISERS SEEN AS PROMISING IDEA (Doc 2018-32998) Tax Notes Today AUGUST 16, 2018, THURSDAY Copyright © 2018 Tax Analysts   Cite: 2018 TNT 159-3 Department: News, Commentary, and Analysis; News Stories Length: 1213 words Byline: Tax Analysts; Richman, Nathan J. Geographic: United States Published by Tax Analysts(R) The conversion […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 10, 2018

This webinar will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting income and gain on cryptocurrency (e.g. Bitcoin, Coinbase) transactions. The panel will discuss the IRS’ position on cryptocurrency as property rather than cash, analyze IRS monitoring to increase compliance, and define proper reporting and tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 08, 2018

2018 TNT 153-1 Ninth Circuit Withdraws Altera Opinion New Judge to Weigh In Tax Notes Today AUGUST 08, 2018, WEDNESDAY Copyright © 2018 Tax Analysts Cite: 2018 TNT 153-1 Department: News, Commentary, and Analysis; News Stories Byline: Tax Analysts; Parillo, Kristen A. Published by Tax Analysts(R) The Ninth Circuit’s just-withdrawn Altera v. Commissioner decision will get a fresh look […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 03, 2018

What is the Potential Maximum Willful FBAR Penalty? In the wake of United States v. Colliot, here, another district court recently held that the regulation at 31 CFR §1030.820 limits the maximum willful penalty.  In United States v Wadhan, here, (D. Colo. July 18, 2018), the Wadhans had one account at UBS.  They closed the UBS account in 2008 and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 03, 2018

In 1998 Congress added §7433(e) to the Code.  It provides that a taxpayer can sue the US for damages as a result of collection action that “willfully violates” either the bankruptcy stay imposed by 11 USC §362 or a bankruptcy discharge order under 11 USC §524.  The statute provides: (e)Actions for violations of certain bankruptcy […] Read More…