TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 20, 2020

Enforcement and compliance is a top priority of the Internal Revenue Service (“IRS”). The IRS has 150 penalties at its disposal to assist in its stated goals of enforcement and obtaining compliance with the tax laws of the United States. Many of these penalties can be assessed not only against taxpayers but also against tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, January 08, 2020

We are pleased to announce that three of our principals will be speaking at the upcoming Strafford webinar on New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops, January 14, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will discuss recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding taxation of cryptocurrency. With […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 06, 2020

SANDRA BROWN quoted in Tax Analysts’ article, “Ride Across the Marinello Bridge Cases Could Be Bumpy.” Sandra R. Brown of Hochman Salkin Toscher Perez PC compared the bridge-case transition with the change in behavior that followed Booker v. United States, 514 U.S. 220 (2005) — the case in which the Supreme Court declared that the sentencing guidelines […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, December 20, 2019

On December 2, 2019, the Internal Revenue Service released Rev. Proc. 2019-42, which applies to any income tax return filed on 2019 tax forms for the 2019 tax year, including 2019 tax forms for short taxable years beginning in 2020 if filed before the forms for 2020 are available.  This updated revenue procedure, which updates […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 18, 2019

the new Taxpayer First Act, among other benefits will bring the IRS into the twenty-first century. It has been more than 20 years since the U.S. Congress addressed taxpayer rights in the Tax Reform and Restructuring Act of 1998.1 In June 2019, H.R. 3151, otherwise known as the Tax payer First Act, was introduced in […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 16, 2019

Gary Markarian is a recent graduate of Loyola Law School’s joint J.D./ Tax LL.M. program, where he graduated with High Distinction. Prior to law school, he graduated from the University of California, Los Angeles, with a B.A. in Political Science. Gary’s prior experience includes working as a law clerk for the Law Offices of Givner & […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 11, 2019

Please join us January 27-29, 2020 for the USC Gould School of Law 2020 Tax Institute at the Millennium Biltmore Hotel, Los Angeles. Learn the latest tax law developments for corporations, privately-held businesses, individuals, partnerships and real estate transactions, and important tax ethics, compliance, enforcement and estate planning solutions. Take away practical tips from over 75 veteran tax professionals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 02, 2019

The IRS recently has become more aggressive in assessing foreign information reporting penalties against taxpayers who fail to file required forms for foreign trusts or who file them late.  For years, we have been writing about the IRS’ enforcement efforts with respect to offshore accounts and assets.   With what has generally been perceived as successfully […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, November 28, 2019

We are pleased to announce that four of our principals will be speaking at the upcoming 36th Annual National Institute on Criminal Tax Fraud, December 11-13, 2019, Wynn, Las Vegas. Co-Chaired by Steven Toscher and Kathryn Keneally.  This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, November 17, 2019

The IRS has spent over a decade using and refining a model for bringing into compliance those taxpayers who made mistakes in good faith or through non-willful ignorance, and for punishing bad actors. The renewed push to target cryptocurrency builds on its predecessor, offshore bank accounts, but is distinguishable in important ways. The IRS appears sensitive to the differences, has more to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, November 11, 2019

Last August, I blogged on the Court of Federal Claims (CFC) decision in the Mindy Norman FBAR willful penalty case.  Rejecting the decisions in Colliot and Waldham, the CFC held that 31 CFR § 1010.820 (which limited the willful FBAR penalty to $100,000) was invalid due to the 2004 amendment to 31 U.S.C. §5321(a)(5).  Disagreeing […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 06, 2019

White-collar prosecutors and defense counsel have noticed a downward trend in the number of fraud cases, including tax cases, since the 9/11 attacks. The FBI and other agencies since then have reallocated their resources to counterterrorism investigations.  However, this re-orientation only accounts for part of the drop; one of the other critical factors has been […] Read More…