TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 28, 2025

We are pleased to announce that Sandra R. Brown along with Caroline Ciraolo (Kostelanetz LLP) and Sharyn Fisk (California State Polytechnic University Pomona) will be speaking at the upcoming Hawaii Tax Institute on Clemency [Pardons and Commutations] – Navigating the Rules, Managing Client Expectations and Ethical Considerations seminar at the Sheraton Waikiki, Wednesday, November 5, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 21, 2025

We are pleased to announce that four of our principals will be speaking at the upcoming UCLA 41st Tax Controversy Conference on Thursday, October 23, 2025 at the Beverly Hills Hotel on the following key topics: Robert S. HorwitzFranchise Tax Board Controversies and the California Office of Tax Appeals Evan J. Davis The Future Direction […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, October 13, 2025

We are all looking forward to the ABA Tax Section 2025 Criminal Tax Fraud and Tax Controversy Conference which will take place on December 11-13, 2025, at the Wynn Las Vegas. The tables are set and the topics ready to roll for what has become one of the most anticipated annual gatherings of criminal and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 07, 2025

On Tuesday, October 21, 2025 at 3:15 p.m., Jonathan Kalinski will be moderating a panel at the ABA Virtual 2025 Fall Tax Meeting entitled “Navigating Tax Issues for Expats.” Co-panelists include Maria Otero (Holland & Knight), and Bryan H. Kelly (Willkie). They will discuss how to avoid or reduce penalties that can arise from failures to file or pay on time, inaccuracies […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, October 03, 2025

We are pleased to announce that Jonathan Kalinski has been appointed to the American Bar Association Taxation Section Appointments to the Tax Court Committee. The committee is responsible for the important task of reviewing the qualifications of individuals who are appointed to the United States Tax Court. Jonathan Kalinski is a Principal of the law […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, October 01, 2025

Two district court opinions issued days apart, United States v. Sagoo, WL 2689912 (N.D. Tex. September 19, 2025), and HDH Group, Inc. v. United States, 2025 WL 2711877 (W.D. Penn. September 23, 2025), reached opposite results to the question of whether the IRS assessment of penalties without a prior jury trial violates the Seventh Amendment. The […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 30, 2025

On October 7, 2025 from 12:30 p.m. – 1:30 p.m. (PST), Evan J. Davis along with Professor Jean Reisz (USC Gould School of Law) will be presenting a webinar on Prosecuting Employment Tax Fraud and Alien Harboring Together: HSI and IRS Join Forces through the Beverly Hills Bar Association. The new administration has made immigration […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 29, 2025

We are pleased to announce that Sandra R. Brown has been appointed Vice-Chair of the American Bar Association Civil and Criminal Tax Penalties Committee for 2025-2026. Sandra’s recognition of this position by her peers, speaks to her abilities and contributions of the ABA Taxation Section. The ABA’s Civil and Criminal Tax Penalties Committee (CCTP) is responsible […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 26, 2025

We’re pleased to announce that Robert S. Horwitz and Philipp Behrendt along with Steven Jager (Fineman West & Company) will be teaching a free live online course on Employee Retention Credit – Enforcement Penalties and Examination Strategies offered by the UCLA Extension Tax Controversy Institute on September 30, 2025 from 12:00 p.m. – 1:30 p.m. (PST). This […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 25, 2025

We are pleased to announce that the Taxation Section of the California Lawyers Association will be presenting Dennis Perez with the prestigious Joanne M. Garvey Award for his lifetime achievement and contributions in taxation. For over thirty-eight (38) years Dennis has been representing clients in civil and criminal tax litigation and tax disputes and controversies before […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 16, 2025

Dear Colleagues- We are now just over a month away from the 2025 UCLA Extension Tax Controversy Institute, which will be held on October 23, 2025, at the historic landmark Beverly Hills Hotel. Continuing the tradition of over 40 years, this year’s 41st Tax Institute is a can’t miss event for tax professionals both locally and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 09, 2025

The foreign tax credit, in fact Subchapter N itself, always seemed impenetrable to me. Only really smart people could understand it, but then Einstein found the income tax “the hardest thing in the world to understand.” Luckily, in Liberty Global, Inc. v. Commissioner, No. 24-9004, __ F.4th __ (August 27, 2025), the Tenth Circuit wrote an abbreviated […] Read More…