Our Blog

Ninth Circuit Holds Time Limit for Filing Challenge to Collection Due Process Determination Is Jurisdictional; Does that Mean Time Limit for Seeking Redetermination of a Deficiency Is Not? by Robert S. Horwitz

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…

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SANDRA R. BROWN First Assistant United States Attorney and the Former Acting United States Attorney for the Central District of California’s United States Attorney’s Office has Joined Our Firm as a Principal

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…

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Message from Chairs Charles Rettig and Steven Toscher

For 33 YEARS, the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation! This year, Steve Toscher and I were honored and privileged to serve as Co-Chairs of The Annual Tax Controversy Institute! Institute Chair Emeritus. The Institute was founded by […] Read More…

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See What Procedurally Taxing is Saying About the New Nominee for IRS Commissioner CHARLES RETTIG

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…

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We Are Pleased to Announce That LACEY STRACHAN Has Been Named Principal Of Our Firm

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…

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Cryptocurrency Tax Webinar Hosted By Colleagues Of IRS Nominee Charles Rettig by Matthew De Silva of ETHNews.COM

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…

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STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules

  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…

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FOR IMMEDIATE RELEASE – President Trump Announces Intent to Nominate CHARLES P. RETTIG to be the Next Commissioner of Internal Revenue

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…

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Criminal Tax Restitution Order Overcomes Later IRS Settlement by Robert S. Horwitz

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…

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Sentencing in Tax Cases: It Ain’t That Bad (for Defendants) by Robert S. Horwitz

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…

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Tax Court Reverses Itself, But The Taxpayer Still Loses by Robert S. Horwitz

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…

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WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

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…

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