TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 04, 2018

The Bipartisan Budget Act of 2018 (“BBA”) President Trump signed into law on February 9, 2018 contains two provisions that clarify and expand whistleblower rights for certain taxpayers. First, Congress broadened the definition of “collected proceeds” for tax whistleblowers under IRC Section 7623(b) to include criminal fines and civil forfeitures.  This definition is relevant for […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 16, 2018

Thursday, May 10, 2018, New York City 10:45 a.m. – 12:15 p.m. Eastern Time Steven Toscher and Michel Stein will be speaking in New York City at an upcoming Strafford seminar/webinar, New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment scheduled for Thursday, May 10th, 10:45 a.m. – 12:15 p.m. EST. Tax reform and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 16, 2018

Steven Toscher and Michel Stein will be speaking at an upcoming Beverly Hills Bar Association presentation, “Cryptocurrency and IRS Tax Enforcement” scheduled for Thursday, May 17th at noon.  Presentation from 12:30 p.m. – 1:30 p.m. The presentation will provide tax professionals with a critical first look at new IRS initiatives on taxpayer compliance and reporting […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 16, 2018

The regulations[1] require that no alien, whether resident or non-resident, can depart from the United States unless he or she first procures a certificate that he or she has complied with the obligations imposed upon him or her by the income tax laws.[2]Failure to do so may result in a termination assessment. Certain types of individuals, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, April 08, 2018

Generally, when a taxpayer files a tax return, the federal tax laws afford the Internal Revenue Service (“IRS”) with a limit of only three-years within which it must act to examine and assess additional taxes and penalties on any unreported income. While the Internal Revenue Code provides various exceptions to this three-year limit[i], on January 2, 2018, the Tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, April 08, 2018

As we approach the tax return filing deadline of April 17 this year, taxpayers are scrambling for documents to substantiate their expenses and basis in assets. Tax practitioners are always asked low long should one keep records.  Three years?  Seven years?  Forever?  If you find yourself without records, all may not be lost thanks to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 30, 2018

There’s been a recent uptick in state and federal prosecutions of restaurants who use sales-suppression software (also known as “zappers”) that delete transactions on computerized point-of-sale systems, as governments have finally woken up to the fact that they are losing tens of billions of dollars per year in underreported sales and income taxes. These zapper […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 27, 2018

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford April 24, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) Due to an overwhelming popularity, Steven Toscher and Michel Stein will be hosting an encore presentation of the Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment” The panel will provide […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 23, 2018

Did you ever fail to keep complete and accurate records? Pay someone in cash? Not give an accountant all your records? Deposit a business check in a personal account? Thanks to the Supreme Court’s March 21 decision in Marinello v United States, 584 U.S. ___, you won’t have to worry that these acts can lead to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 15, 2018

When it comes to taxes, Congress is penalty happy. There are over 150 separate penalties that can be imposed for various infractions of the Internal Revenue Code.  Two recent IRS pronouncements address penalties. First Time Abatement Relief Among the myriad of penalties, the Internal Revenue Code provides for the penalties for: Failure to file a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 07, 2018

In recent years, the United States Supreme Court has wrestled with the issue of whether time limits for bringing administrative and judicial actions against the Federal Government jurisdictional. In Sebelius v Auburn Regional Medical Center, 568 U.S. __, Justice Ginsburg, writing for the majority, stated: Characterizing a rule as jurisdictional renders it unique in our […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 04, 2018

HOCHMAN SALKIN RETTIG TOSCHER & PEREZ. PC announced that SANDRA BROWN, former Acting United States Attorney of the Central District of California, will join the Firm as a Principal on March 5, 2018, where she will handle all phases of civil and criminal tax controversies, including trials and appeals. CHARLES RETTIG, Managing Principal of the […] Read More…