TAXLITIGATOR Blog

IRS Targets Monetized Installment Sales by STEVEN TOSCHER, ROBERT HORWITZ and PHILIPP BEHRENDT

IRS Targets Monetized Installment Sales by STEVEN TOSCHER, ROBERT HORWITZ and PHILIPP BEHRENDT

In an effort to combat tax evasion and abusive tax transactions, the Internal Revenue Service (IRS) and the U.S. Treasury Department have recently released proposed regulations targeting monetized installment sale transactions. These transactions, along with substantially similar schemes, have been classified as listed transactions—a category of reportable transactions that requires special disclosure and reporting. Click […] Read More…

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PHILIPP BEHRENDT to Speak at Upcoming California Lawyers Association Webinar

PHILIPP BEHRENDT to Speak at Upcoming California Lawyers Association Webinar

We are pleased to announce that Philipp Behrendt will be speaking at the upcoming California Lawyers Association webinar “The Use of AI for Tax Litigation,” Tuesday, August 8, 2023, 12:00 p.m. – 1:00 p.m. (PST). The webinar will delve into the transformative impact of artificial intelligence on tax litigation practices. Attendees can look forward to gaining valuable […] Read More…

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8th Annual USD School of Law – RJS LAW Tax Controversy Institute

8th Annual USD School of Law – RJS LAW Tax Controversy Institute

Our partners, Dennis Perez and Sandra Brown, had the privilege of speaking in San Diego on Friday at the 8th Annual USD School of Law- RJS LAW Tax Controversy Institute.  Joining Dennis Perez on the Government Loans Panel, which provided an in depth focused on PPP, EIDL and ERC audit and fraud issues, were AUSA Dylan […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and PHILIPP BEHRENDT to Speak at Upcoming CalCPA Webinar

STEVEN TOSCHER, MICHEL STEIN and PHILIPP BEHRENDT to Speak at Upcoming CalCPA Webinar

We are pleased to announce that Steven Toscher, Michel Stein, and Philipp Behrendt will be speaking at the upcoming CalCPA webinar “Cryptocurrency Compliance 2023,” Tuesday, August 8, 2023, 9:00 a.m. – 10:00 a.m. (PST). Keep abreast of the IRS’s continuous efforts to enhance compliance in the crypto space. Join us for a practical look at the […] Read More…

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EVAN DAVIS and CORY STIGILE to Speak at Upcoming CalCPA 2023 Annual Income Tax Seminar

EVAN DAVIS and CORY STIGILE to Speak at Upcoming CalCPA 2023 Annual Income Tax Seminar

Please join us July 28, 2023 for the CalCPA 2023 Annual Income Tax Seminar. We have an excellent line up of programs – How to Help an Individuals with Unreported or Misreported Crypto Transactions(8:05 a.m. – 9:25 a.m. PST)Featuring Evan Davis R&D Credit Hot Topic and California Considerations(1:05 p.m. – 2:20 p.m. PST)Featuring Cory Stigile The […] Read More…

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IRS Steps Up Civil and Criminal Tax Enforcement Regarding Employee Retention Credit by STEVEN TOSCHER and PHILIPP BEHRENDT

IRS Steps Up Civil and Criminal Tax Enforcement Regarding Employee Retention Credit by STEVEN TOSCHER and PHILIPP BEHRENDT

The Employee Retention Credit (ERC) has been a lifeline for businesses struggling during the COVID-19 pandemic. Designed to provide financial assistance to eligible employers who kept their workforce employed during times of economic hardship, the ERC has proven to be a vital source of support for many. However, with its increasing popularity, aggressive marketing tactics, […] Read More…

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JONATHAN KALINSKI Quoted in Tax Notes

JONATHAN KALINSKI Quoted in Tax Notes

Jonathan Kalinski quoted in Tax Notes article on newly filed Tax Court cases challenging the IRS’ position in applying IRC Section 280E to Offers in Compromise for marijuana businesses. Offers in Compromise are challenging for marijuana businesses because the IRS uses 280E disallowed expenses in determining collection potential, creating a phantom cash problem.  “The fiction of […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming CPA Academy Webinar

STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming CPA Academy Webinar

We are pleased to announce that Steven Toscher, Michel Stein, and Sandra Brown will be speaking at the upcoming CPA Academy webinar “Tax Controversy Hot Topics,” Tuesday, July 25, 2023, 8:00 a.m. – 9:00 a.m. (PST). This webinar will cover critical practice and procedural issues facing practitioners, including IRS priorities, the new emphasis on fraud investigations, […] Read More…

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DENNIS PEREZ and SANDRA BROWN to Speak at Upcoming USD School of Law – RJS Law Tax Controversy Institute

DENNIS PEREZ and SANDRA BROWN to Speak at Upcoming  USD School of Law – RJS Law Tax Controversy Institute

Please join us July 28, 2023 for the USD School of Law – RJS Law Tax Controversy Institute at the San Diego Knauss Center for Business Education, Nexus Theater University of San Diego. We have an excellent line up of programs – A Guide to IRS Criminal Tax Investigations and Prosecutions Featuring Sandra Brown IRS Cares about […] Read More…

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Third Circuit Holds the Ninety-Day Period for Petitioning the Tax Court for Redetermination Is Not Jurisdictional by ROBERT S. HORWITZ and PHILIPP BEHRENDT

Third Circuit Holds the Ninety-Day Period for Petitioning the Tax Court for Redetermination Is Not Jurisdictional by ROBERT S. HORWITZ and PHILIPP BEHRENDT

For more than 85 years the Tax Court, its predecessor, the Board of Tax Appeals, and those courts of appeal that addressed the issue, held that the statute of limitations for filing a petition for redetermination was jurisdictional. When a prerequisite for a lawsuit is jurisdictional, it means that if the prerequisite has not been met, […] Read More…

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Puerto Rico Tax Break Controversy: IRS Targets Crypto Traders, Hedge Fund Managers, and other Wealthy Individuals by PHILIPP BEHRENDT

Puerto Rico Tax Break Controversy: IRS Targets Crypto Traders, Hedge Fund Managers, and other Wealthy Individuals by PHILIPP BEHRENDT

Puerto Rico has been offering tax incentives to wealthy individuals, hedge fund managers, and cryptocurrency traders since 2012. These tax incentives have allowed them to legally avoid paying federal income tax and certain other taxes. However, recent developments have brought these tax breaks under scrutiny, with US prosecutors and IRS agents launching criminal and civil […] Read More…

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STEVEN TOSCHER Quoted in Tax Notes

STEVEN TOSCHER Quoted in Tax Notes Read More