TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 10, 2024

In 2015 Congress enacted the Bipartisan Budget Act of 2015 (“BBA”) that, among other things, repealed the TEFRA partnership audit provisions and replaced them with BBA partnership audit provisions effective for partnership tax years beginning after December 31, 2017. Both the TEFRA and BBA partnership audit provisions provided for an audit and adjustments at the partnership […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 07, 2024

We are pleased to announce that Steven Toscher, Sandra R. Brown and Robert Horwitz will be speaking at the upcoming CalCPA webinar “IRS Scrutiny of ERCs” Tuesday, June 11, 2024, 9:00 a.m. – 10:30 a.m. (PST). The employee retention credit, enacted as part of the CARES Act, is a US federal tax credit that provides an […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 06, 2024

We are pleased to announce that Sandra R. Brown will be receiving the prestigious Richard Carpenter Excellence in Tax Award from the USD School of Law – RJS LAW Tax Controversy Institute. The Award is being presented at the 9th Annual USD School of Law – RJS LAW Tax Institute taking place July 19th in San […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 03, 2024

We are pleased to announce that Michel R. Stein and Philipp Behrendt will be speaking at the upcoming CSTC San Francisco Chapter webinar on “Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations & Tax Treatment of Digital Currency,” on Wednesday, June 5, 2024 from 6:00 p.m. – 8:00 p.m. (PST). Cryptocurrency has exploded over […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 22, 2024

We are pleased to announce that Steven Toscher, Michel R. Stein and Thomas M. Giordano-Lascari (Greenberg Glusker) will be speaking at the upcoming Strafford webinar “IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process” Tuesday, May 28, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS has and continues to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 20, 2024

Sandra R. Brown was quoted in a May 6, 2024 Tax Notes Article on What the IRS’s 2024 ‘Dirty Dozen’ List Tells Us About Tax Administration, authored by Kathy A. Enstrom, Moore Tax Law Group, LLC.  The IRS annually releases its “Dirty Dozen” list to warn taxpayers and tax practitioner alike of various tax scams as […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 15, 2024

In a recent interview with CNBC at the Chainalysis Links event in New York, Guy Ficco, a Chief of the IRS Criminal Investigation Division (IRS-CI), issued a stark warning: the IRS is gearing up to tackle a significant increase in cases of tax fraud and evasion related to cryptocurrency transactions. Ficco’s words carry weight, especially […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 10, 2024

We are pleased to announce that Steven Toscher, Michel R. Stein and Cory Stigile will be speaking at the upcoming Strafford webinar “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation” Wednesday, May 15, 2024, 10:00 a.m. – 11:50 a.m. (PST). The IRS Large Business and International Division is auditing high net […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 09, 2024

We are pleased to announce that on May 17, 2024, Sandra R. Brown, along with Gwen Moore (Moore Tax Law Group), Jennifer Breen (Morgan Lewis), and Pamela Grewal (Andersen Tax), will join a webinar with the Loretta Collins Argrett fellows and leadership to discuss navigating their career transitions and what it means to be a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 08, 2024

My co-chair, Kathy Keneally and I are very pleased to ask you to save the date for the ABA 2024 Criminal Tax Fraud/Tax Controversy conference, to be held this year at the Wynn Encore on December 12-14, 2024.  The program is still in the planning stage, but we can assure you that we continue to build […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 07, 2024

We are pleased to announce that Steven Toscher, Michel R. Stein and Evan Davis will be speaking at the upcoming Strafford webinar “Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations” Thursday, May 9, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS continues to press its concern over “massive under-reporting” of income from cryptocurrency transactions, including […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 06, 2024

Steven Toscher, the managing principal for Hochman Salkin Toscher Perez P.C., has received the Jules Ritholz Memorial Merit Award from The American Bar Association’s (ABA) Tax Section Civil and Criminal Tax Penalties Committee. The award was presented during ABA’s 2024 May Tax Meeting, held in Washington, DC. on May 3, 2024.  Click Here to Read […] Read More…