TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, April 08, 2018

As we approach the tax return filing deadline of April 17 this year, taxpayers are scrambling for documents to substantiate their expenses and basis in assets. Tax practitioners are always asked low long should one keep records.  Three years?  Seven years?  Forever?  If you find yourself without records, all may not be lost thanks to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 30, 2018

There’s been a recent uptick in state and federal prosecutions of restaurants who use sales-suppression software (also known as “zappers”) that delete transactions on computerized point-of-sale systems, as governments have finally woken up to the fact that they are losing tens of billions of dollars per year in underreported sales and income taxes. These zapper […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 27, 2018

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford April 24, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) Due to an overwhelming popularity, Steven Toscher and Michel Stein will be hosting an encore presentation of the Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment” The panel will provide […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 23, 2018

Did you ever fail to keep complete and accurate records? Pay someone in cash? Not give an accountant all your records? Deposit a business check in a personal account? Thanks to the Supreme Court’s March 21 decision in Marinello v United States, 584 U.S. ___, you won’t have to worry that these acts can lead to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 15, 2018

When it comes to taxes, Congress is penalty happy. There are over 150 separate penalties that can be imposed for various infractions of the Internal Revenue Code.  Two recent IRS pronouncements address penalties. First Time Abatement Relief Among the myriad of penalties, the Internal Revenue Code provides for the penalties for: Failure to file a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 07, 2018

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 04, 2018

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 23, 2018

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…

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…