TAXLITIGATOR Blog
Dueling Districts: Does IRS Assessment of a Penalty Without Jury Trial Violate the Seventh Amendment? by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, October 01, 2025
Two district court opinions issued days apart, United States v. Sagoo, WL 2689912 (N.D. Tex. September 19, 2025), and HDH Group, Inc. v. United States, 2025 WL 2711877 (W.D. Penn. September 23, 2025), reached opposite results to the question of whether the IRS assessment of penalties without a prior jury trial violates the Seventh Amendment. The […] Read More…
Read MoreEvan J. Davis to Speak at Upcoming Beverly Hills Bar Association Webinar on Prosecuting Employment Tax Fraud and Alien Harboring Together
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 30, 2025
On October 7, 2025 from 12:30 p.m. – 1:30 p.m. (PST), Evan J. Davis along with Professor Jean Reisz (USC Gould School of Law) will be presenting a webinar on Prosecuting Employment Tax Fraud and Alien Harboring Together: HSI and IRS Join Forces through the Beverly Hills Bar Association. The new administration has made immigration […] Read More…
Read MoreSandra R. Brown Appointed Vice-Chair of the ABA Taxation Section Civil and Criminal Tax Penalties Committee
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 29, 2025
We are pleased to announce that Sandra R. Brown has been appointed Vice-Chair of the American Bar Association Civil and Criminal Tax Penalties Committee for 2025-2026. Sandra’s recognition of this position by her peers, speaks to her abilities and contributions of the ABA Taxation Section. The ABA’s Civil and Criminal Tax Penalties Committee (CCTP) is responsible […] Read More…
Read MoreRobert S. Horwitz and Philipp Behrendt to Speak at the Upcoming UCLA Extension Tax Controversy Institute: Employee Retention Credit – Enforcement, Penalties, and Examination Strategies
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 26, 2025
We’re pleased to announce that Robert S. Horwitz and Philipp Behrendt along with Steven Jager (Fineman West & Company) will be teaching a free live online course on Employee Retention Credit – Enforcement Penalties and Examination Strategies offered by the UCLA Extension Tax Controversy Institute on September 30, 2025 from 12:00 p.m. – 1:30 p.m. (PST). This […] Read More…
Read MoreDennis Perez to Receive California Lawyers Association 2025 Joanne M. Garvey Award
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 25, 2025
We are pleased to announce that the Taxation Section of the California Lawyers Association will be presenting Dennis Perez with the prestigious Joanne M. Garvey Award for his lifetime achievement and contributions in taxation. For over thirty-eight (38) years Dennis has been representing clients in civil and criminal tax litigation and tax disputes and controversies before […] Read More…
Read More41st Annual UCLA Tax Controversy Conference – October 23, 2025
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 16, 2025
Dear Colleagues- We are now just over a month away from the 2025 UCLA Extension Tax Controversy Institute, which will be held on October 23, 2025, at the historic landmark Beverly Hills Hotel. Continuing the tradition of over 40 years, this year’s 41st Tax Institute is a can’t miss event for tax professionals both locally and […] Read More…
Read MoreThe Tenth Circuit Provides a Crash Course in the Foreign Tax Credit by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 09, 2025
The foreign tax credit, in fact Subchapter N itself, always seemed impenetrable to me. Only really smart people could understand it, but then Einstein found the income tax “the hardest thing in the world to understand.” Luckily, in Liberty Global, Inc. v. Commissioner, No. 24-9004, __ F.4th __ (August 27, 2025), the Tenth Circuit wrote an abbreviated […] Read More…
Read MoreWith Strikes in the Third and Now the Second and Sixth Circuits, Will the Commissioner Admit He Is Out on the Claim that the 90-Day Deadline for Filing a Tax Court Petition Is Jurisdictional? by Robert Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 08, 2025
On August 14 and August 25, 2025, the Second Circuit in Buller v. Commissioner, ___ F.4th ___, 2025 WL 2348969, and the Sixth Circuit in Oquendo v. Commissioner, ___ F.4th ___, 2025 WL 2434542, joined the Third Circuit in Culp v. Commissioner, 75 F.4th 196 (2023), in holding that Internal Revenue Code (“IRC”) §6213(a)’s 90-day deadline […] Read More…
Read MoreRecognition of Philipp Behrendt in Best Lawyers: Ones to Watch
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 29, 2025
We are very proud to announce that our colleague and associate, Philipp Behrendt, has been recognized in the 2026 edition of Best Lawyers: Ones to Watch in America. This honor is awarded to outstanding attorneys who are early in their careers and have demonstrated exceptional professional excellence in private practice. The Best Lawyers: Ones to […] Read More…
Read MoreEvan J. Davis to Speak at Upcoming 42nd International Symposium on Economic Crime
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 28, 2025
On September 1, 2025, Evan J. Davis will be moderating a panel at the 42nd International Symposium on Economic Crime entitled “Cross-Border Financial Crimes: Recent U.S. Prosecutions and Investigation Priorities,” at Jesus College, Cambridge. Co-panelists include Caroline Ciraolo (Kostelanetz LLP), Larry Campagna (Chamberlain Hrdlicka), and Jeff Neiman (Neiman Mays Floch & Almeida PLLC). Our topics will […] Read More…
Read MoreTax Court Holds There Is No Right to a Jury Trial on Liability for a Civil Fraud Penalty by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 26, 2025
The 7th Amendment to the U.S. Constitution states that “[i]n Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved.” Last year, the Supreme Court in SEC v. Jarkesy, 603 U.S. 109 (2024), held that under the 7th Amendment a person was entitled to […] Read More…
Read MoreSebastian Voth to Speak at Upcoming TexasBarCLE Live Webcast – Using FOIA in Your Practice
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 21, 2025
We’re pleased to announce that Sebastian Voth will be presenting at the TexasBarCLE 43rd Annual Course, Tax Law in the Digital Age, via live webcast on Thursday, August 28, 2025, at 7:30 AM (PST). The presentation, Using FOIA in Your Practice, will explore how and when tax practitioners should submit Freedom of Information Act (FOIA) […] Read More…
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