TAXLITIGATOR Blog
Tax Notes -The Outer Bounds of Discretionary Sentencing in Criminal Tax Cases by STEVEN TOSCHER
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Sunday, June 23, 2019
In this article, Toscher examines the judicial evolution of sentencing in federal tax cases under the non-mandatory guidelines. Before the promulgation of the federal sentencing guidelines effective November 1, 1987, the sentence of an individual convicted of a federal tax crime was discretionary with the trial court. That changed with the federal sentencing guidelines because of the concerns for […] Read More…
Read MoreSTEVEN TOSCHER and MICHEL STEIN Quoted in Law360 Article on Upcoming Cryptocurrency Guidance From IRS
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 07, 2019
STEVEN TOSCHER and MICHEL STEIN are quoted in Law360’s article, “Expect IRS Crypto Guidance On Basis, Hard Forks, Attys Say. Highly anticipated IRS guidance on cryptocurrency will likely address cost basis and the treatment of hard forks, or the splitting of cryptocurrency blockchain, and will likely be more authoritative than guidance put out in 2014, […] Read More…
Read MoreIRS to Strengthen Its Taxpayer Fraud Referral Procedures by STEVEN TOSCHER
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 07, 2019
The Treasury Inspector General for Tax Administration Issued a report to the IRS Commissioner on May 23, 2019 pointing the way to increasing the efficacy of its Information Referral Program to increase tax compliance and raise revenue. The IRS has long had a program where the public could report to the IRS alleged non-compliance with […] Read More…
Read More11th Circuit Holds that “My Boss Told Me Not to Pay” Is Not a Defense to Trust Fund Penalties, Even Where the Boss Is a Government Agency by LACEY STRACHAN
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 03, 2019
The general rule is that under IRC Section 6672(a), a person “required to collect, truthfully account for, and pay over any tax…who willfully fails to collect such tax, or truthfully account for and pay over such tax” (known as trust fund taxes) is liable for a penalty equal to the total amount of the tax […] Read More…
Read MoreWishing our Longtime Legal Assistant JULIE TAKEMOTO a Happy Retirement!
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 03, 2019
It is with mixed emotions that we announce the retirement of our longtime legal assistant, Julie Takemoto. Julie has been a part of the Hochman Salkin family since 1981 and has helped shape the firm into what it is today. Her hard work and dedication to others is a reflection of the culture and success […] Read More…
Read MoreDENNIS PEREZ to speak at the upcoming Oregon Tax Institute entitled “Current IRS Enforcement Objectives, Ways in which IRS Detects and Pursues these Objectives and Taxpayer Defense Alternatives,” Multnomah Athletic Club, Portland, Oregon
Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, June 02, 2019
We are pleased to announce that Dennis Perez will be presenting at the upcoming Oregon Tax Institute, June 6-7, 2019. From important court decisions to the Tax Cuts and Jobs Act(“TCJA”), the 2019 Oregon Tax Institute will cover a range of state and federal tax topics to help ensure practitioners are best situated to advise […] Read More…
Read MoreSTEVEN TOSCHER and DENNIS PEREZ to speak at the upcoming NYU 11th Annual Tax Controversy Forum
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 29, 2019
We are pleased to announce that two of our principals will be speaking at the upcoming 11th Annual Tax Controversy Forum at Crowne Plaza Times Square, Manhattan, New York on June 20 and 21. For more information Click Here. Steven Toscher will be speaking on Litigating Foreign Asset Reporting Tax Penalties: The Controversies Continue. It’s […] Read More…
Read MoreA District Court Enforces a John Doe Summons Issued to a Law Firm (Prefaced by a Brief Primer on John Doe Summonses) by ROBERT S. HORWITZ
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 27, 2019
Administrative summonses are an important investigative tool of the IRS in fulfilling its statutory duty of “proceeding from time to time, through each internal revenue district and inquire after and concerning all persons who may be liable to pay any internal revenue tax.” Internal Revenue Code (“IRC”) §7601(a). Where a person served a summons fails […] Read More…
Read MoreTax Court Holds IRS Can Assess, Collect Restitution Notwithstanding District Court Payment Schedule by ROBERT S. HORWITZ
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 27, 2019
In 2010, Congress amended Internal Revenue Code (IRC) sec. 6201 by adding subsection (a)(4), which authorizes the IRS to assess and collect the amount of criminal restitution ordered for failure to pay any tax in the same manner as if the restitution was a tax. The assessment could be made at any time after all […] Read More…
Read MoreFinCEN Amps Up Virtual Currency Regulation and Warns About Misuse of VC by EVAN DAVIS
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 21, 2019
The government continues to show its presence regulating virtual currency and enforcing civil and criminal laws in this developing area. Our Firm has had a number of clients involved in civil tax and criminal (tax, securities, and Bank Secrecy Act (“BSA”)) investigations, and the Government continues to show its active presence. FinCEN (Financial Crimes Enforcement […] Read More…
Read MoreHOCHMAN SALKIN TOSCHER PEREZ P.C. Proud Sponsor of the CalCPA 7th ANNUAL 5K BEACH RUN AND WALK
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 20, 2019
Join CalCPA and the Sean Brock Foundation in a charity run which will include a 5K run and walk, 10K run and a 1K(ish) kids run. You’ll enjoy the scenic water views along Dockweiler State Park while giving back to a worthwhile cause. So, get your teams ready for some friendly competition and help raise scholarships […] Read More…
Read MoreTax Notes -Now I Am a C Corp: What About the Accumulated Earnings Tax? by CORY STIGILE
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 15, 2019
In this article, Cory Stigile provides background on the accumulated earnings tax and explains the steps corporate taxpayers may be able to take if the government begins to more actively audit and litigate the accumulation of profits. The Tax Cuts and Jobs Act reduced the corporate tax rate from 35 percent to 21 percent, providing […] Read More…
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