TAXLITIGATOR Blog

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 03, 2014

“If any part of any underpayment of tax required to be shown on a return is due to fraud,” Code section 6663(a) imposes a penalty of 75% of the portion of the underpayment due to fraud. A civil fraud penalty case may be developed based on facts and circumstances of a civil examination or result […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 17, 2014

Contrary to popular belief, the IRS remains active in their core business operations of conducting taxpayer examinations. Returns are identified for examination through an internal IRS process designed to identify issues and returns having significant audit potential. The IRS has been attempting to identify and reduce non-compliance through efficiency, tax form simplification, education, and enforcement. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 26, 2013

Following the examination of a taxpayer’s tax return, the Internal Revenue Service (IRS) might issue a Notice of Deficiency setting forth the proposed adjustments to a taxpayers tax return and the resulting liabilities for tax, interest and penalties arising from the underlying examination. Section 6213(a) of the Internal Revenue Code (Code) provides that, without having […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, November 10, 2013

On October 28, 2013 the IRS revised the Internal Revenue Manual (IRM) providing guidance and clarification regarding the administrative review of FBAR penalties by the IRS Office of Appeals. See https://www.irs.gov/irm/part8/irm_08-011-006.html The IRM is essentially the operational manual providing guidance and procedures for the various functions carried out by the IRS. The Office of  Appeals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, November 01, 2013

The Internal Revenue Service warned consumers about a sophisticated phone scam targeting taxpayers, including recent immigrants, throughout the country. SeeIR-2013-84 (Oct. 31, 2013) at irs.gov NOTE: THE IRS WOULD RARELY, IF EVER, FIRST CONTACT A TAXPAYER BY TELEPHONE. THE FIRST CONTACT IS TYPICALLY IN WRITING AND WOULD BE RECEIVED BY U.S. MAIL. THE IRS WILL […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, October 12, 2013

Historically, Internal Revenue Service examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 08, 2013

The current lapse in federal appropriations does not affect the federal tax law, and all taxpayers should continue to meet their tax obligations as normal. Individuals and businesses should keep filing their tax returns and making deposits with the IRS, as required by law. The Internal Revenue Service reminded taxpayers that the Oct. 15 deadline […] Read More…