TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 20, 2018

Procedurally Taxing February 20, 2018 by: Keith Fogg The press reports that President Trump would nominate Chuck Rettig as the new IRS Commissioner were followed with a formal announcement. Assuming he is confirmed, Mr. Rettig will serve as the first tax lawyer in this position in the new millennium. I applaud the return to having someone run the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 20, 2018

Lacey Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecutions (jury and non-jury) before the federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals. Ms. Strachan represents individuals, corporations, pass-through entities, trusts, and estates in all stages of state and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 16, 2018

On February 15, 2018, tax attorneys Steven Toscher and Michel R. Stein, principals at Hochman Salkin Rettig Toscher & Perez P.C., delivered a presentation entitled “New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment.” Earlier this month, President Trump nominated Charles Rettig, one of Toscher and Stein’s colleagues, to serve as commissioner of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 12, 2018

  Friday, February 16, 2018 12:00 p.m. – 1:30 p.m. Northern Trust 2049 Century Park East, Suite 3600 Los Angeles, CA 90067 Steven Toscher of Hochman Salkin Rettig Toscher & Perez and John Apuzzo of PricewaterhouseCoopers LLP, will discuss an interesting topic about the encore presentation the Strafford webinar, “Form 5471 Substantial Compliance Rules: New […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 09, 2018

HOCHMAN SALKIN RETTIG TOSCHER AND PEREZ, PC is honored to announce that President Trump has announced his intention to nominate Charles P. (“Chuck”) Rettig to become the next Commissioner of the Internal Revenue Service.  If confirmed by the U.S. Senate, Chuck would be the 49th IRS Commissioner, the first “tax person” to assume that position […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 05, 2018

The Government routinely seeks a restitution order in criminal tax cases. When a defendant pleads guilty to a tax crime, the U.S. will either require the taxpayer to agree to a restitution amount or acknowledge that the U.S. can request restitution as part of the sentence.  Once the restitution order is entered, the defendant cannot […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 01, 2018

The Federal Sentencing Commission keeps track of sentencing in federal criminal cases. Its recently released Data Report gives an idea of sentences in criminal tax cases and how they stack up against sentencing in other types of federal criminal cases.  First, some basics. The report is for the fourth quarter of 2017. Since the U.S. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 19, 2018

On November 20, 2017, the Tax Court issued its opinion in Graev v. Commissioner, 149 T.C. __, reversing a prior decision that sustained a 20% accuracy penalty.  The issue before the Court was whether the IRS has to prove that it complied with Internal Revenue Code §6751(b)(1) in order to sustain a penalty in a deficiency […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 19, 2018

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford  February 15, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) On February 15 Steven Toscher and Michel Stein will be hosting a Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment”   The panel will provide tax counsel, accountants and other advisers with […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 19, 2018

FBAR 2018 Update: Mastering FinCen Form 114 Deadlines, Extension, Penalty Resolution and Waiver Provisions Strafford  February 1, 2018 – 10:00 a.m. – 11:50 p.m. (Pacific) On February 1 Michel Stein will be hosting a Strafford Webinar “FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions”  The IRS announced more changes to the filing requirements […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, January 16, 2018

As part of its crackdown on taxpayers who were not reporting income from overseas assets, in 2010 Congress enacted Internal Revenue Code sec. 6038D. That section requires a taxpayer to provide information about “specified foreign financial assets.”  It applies to tax years beginning after March 18, 2010.  The IRS developed Form 8938, Statement of Specified […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 11, 2018

This is the first in a series of blogs that will analyze the IRS’s Fiscal Year 2017 Annual Report. This blog will focus on the shift away from easy cases in favor of harder cases such as foreign-account and hidden-income cases that most consider the core of IRS criminal enforcement. Later blogs will take a […] Read More…