TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 25, 2014

For more than a year, numerous taxpayers with previously undisclosed interests in foreign financial accounts and assets have been seeking participation in the current IRS offshore voluntary disclosure program (the OVDP) which began in 2012, modeled after similar programs in 2009 and 2011. Taxpayers participating in the OVDP generally agree to file amended returns and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 21, 2014

The IRS Large Business & International (LB&I) Division recently issued three recent Directives relating to the issuance and enforcement procedures regarding Information Document Requests (IDRs)(See previous Blog “NEW IRS LB&I Revised IDR Enforcement Process“).[1] LB&I is generally responsible for examinations of wealthy individuals, closely held entities and partnerships, corporations, and S-corporations with assets greater than $10 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 18, 2014

Variations of this informal IRS information discovery process are anticipated to spread throughout the remaining examination functions of the IRS. The IRS Large Business & International (LB&I) Division recently issued three recent Directives relating to the issuance and enforcement procedures regarding Information Document Requests (IDRs).[1] LB&I is generally responsible for examinations of wealthy  individuals, s-corporations, partnerships and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 13, 2014

To download a great article regarding “Procedural Challenges to Interest and Penalties in CDP” prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates Newsletter https://origin.library.constantcontact.com/download/get/file/1109538512255-80/A%26A+Newsletter+%28April+2014%29.pdf The article begins “One of the challenges in collection due process  proceedings is convincing the Internal […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 12, 2014

A “real estate professional” may treat rental real estate activities as non-passive if the taxpayer “materially participates” in the rental activities. Taxpayers claiming to be a real estate professional should contemporaneously document their efforts with respect to each real estate activity. A taxpayer is generally allowed deductions for certain business and profit-seeking investment expenses[1]. However, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 10, 2014

Beginning with tax year 2013 returns (filed in 2014), taxpayers may elect to use a simplified “safe harbor” option when figuring the deduction for business use of their home. Recognizing that the calculation, allocation, and substantiation of allowable deductions attributable to the use of a portion of the taxpayer’s residence for business purposes can be complex and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, March 08, 2014

The Internal Revenue Service recently released a new YouTube video designed to provide useful tax tips to married same-sex couples[1]. The video is less than two minutes long, is available in English, Spanish and American Sign Language and can be accessed via IRS.gov. More than 150 topics covered in various online IRS instructional videos ranging from […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 06, 2014

The Internal Revenue Service recently announced the release of its IRS Criminal Investigation (CI) Annual Report for fiscal year 2013[1], identifying their investigative priorities for 2014 and reflecting significant increases in criminal tax enforcement actions around the country.[2] CI investigates potential criminal violations of the Internal Revenue Code (Code) and related financial crimes. Together with local […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 05, 2014

The Internal Revenue Service recently issued its annual “Dirty Dozen” list of tax scams (IR-2014-16, Feb. 19, 2014), compiled each year identifying a variety of common scams taxpayers can encounter at any point during the year. Seehttps://www.irs.gov/uac/Newsroom/IRS-Releases-the-“Dirty-Dozen”-Tax-Scams-for-2014;-Identity-Theft,-Phone-Scams-Lead-List  Many of these schemes peak during filing season as people prepare their tax returns. “Taxpayers should be on […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 25, 2014

The Permanent Subcommittee on Investigations (PSI) of the United States Senate will hold a hearing, “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore Accounts,” on Wednesday, February 26, 2014, beginning at 9:30 a.m., in Room G-50 of the Dirksen Senate Office Building. See https://www.hsgac.senate.gov/subcommittees/investigations/hearings/offshore-tax-evasion-the-effort-to-collect-unpaid-taxes-on-billions-in-hidden-offshore-accounts The PSI is the chief […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 05, 2014

The number of criminal tax prosecution referrals each year by the Internal Revenue Service (IRS) to the U.S. Department of Justice (DoJ) has risen by nearly a quarter — 23.4 percent — during the administration of President Obama (FY 2009-2013) when compared with the George W. Bush years (2001-2008) according to a February 4, 2014 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 04, 2014

People who owe taxes to the United States often ask whether they might be detained entering or leaving the U. S. In 2008, Charles and Kathleen Barrett filed a fraudulent tax return for the 2007 tax year that resulted in a $217,615 tax refund to which they were not entitled.[1] The Internal Revenue Service discovered […] Read More…