TAXLITIGATOR Blog

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

We are pleased to announce that Edward Robbins, Jr. will be speaking on Wisdom Across the Generations: How to Address Ethical Challenges in Tax Practice at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 2:15 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 21, 2018

We are pleased to announce that Dennis Perez will speak on Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures In a Post-Program World at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Friday, December 14, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 14, 2018

We are pleased to announce that Robert Horwitz will be speaking at an upcoming webinar on Overcoming FBAR Penalties: Best Practices and Practical Tips, January 17, 2019, 9:00 a.m. to 11:00 a.m. (PST)/12:00 p.m. – 2:00 p.m. (ET). Over the years, the Internal Revenue Service (IRS) has enforced drastic penalties for inaccurate, late, and non-filing […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 14, 2018

We are pleased to announce that Sandra Brown will be speaking on Criminal Trial Practice/Ask the Experts at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 14, 2018 from 1:30 p.m. to 3:00 p.m. The most difficult topics […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, November 14, 2018

We are pleased to announce that Sandra Brown will be Co-Moderator of the Criminal Tax Workshop at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 9:30 a.m. to 12:00 p.m. Taxpayers can become aware they […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, November 12, 2018

UCLA Extension is proud to support our veterans as they look to gain new skills and aim to advance their careers through the new Vets Count Scholarship Fund. Vets Count is for active and retired military personnel who are working to realize their career goals in tax, accounting, wealth management, and other areas of the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, November 03, 2018

When a partnership wants to sell real property it sometimes has a problem: some of the partners want to cash out while others want to do a like-kind exchange and remain invested in real property.  The “drop and swap” transaction was designed to address this problem.  Prior to the sale, the partnership distributes, in exchange […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, November 03, 2018

Ten years after starting to aggressively pursue Swiss banks that helped U.S. persons evade taxes, the IRS is continuing to mine the trove of information gathered to criminally pursue the account holders and their facilitators. A pair of practitioners with extensive experience at the IRS said U.S. taxpayers with undisclosed foreign accounts who do not […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, October 29, 2018

Is this merely a theoretical problem? No. The IRS and Justice Department are pursuing Kovel communications aggressively. Lawyers who aren’t careful about how and when they use Kovel accountants are at serious risk of losing privilege protections and giving the government a window into the attorney-client relationship. Although it’s impossible to entirely avoid risk in this area, here are suggestions […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, October 28, 2018

Avram Salkin, a noted tax lawyer who has practiced in Beverly Hills for the past 58 years on Tuesday at The Beverly Hills Hotel received the prestigious Bruce Hochman Award from the UCLA Tax Controversy as part of the 34th annual Tax Institute in recognition of this lifetime achievement in the practice of tax law. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, October 25, 2018

Pro se petitioners James and Tina Loveland hit a home run in a CDP case that resulted in a formal Tax Court opinion, Loveland v. Commissioner, 151 T.C. No. 7 (September 25, 2018), here.  The Tax Court has three levels of opinions: 1) a formal Tax Court opinion, which is published in the Tax Court Reporter and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, October 25, 2018

DEDUCTIBILITY AND INFORMATION REPORTING OF RESTITUTION PAYMENTS: TRANSITIONAL GUIDANCE ISSUED The Tax Cuts & Jobs Act made significant changes to Section 162(f) with respect to the deductibility of certain fines, penalties, and other amounts, including restitution payments. Previously, Section 162(f) barred a deduction for fines or penalties paid to a government for the violation of […] Read More…