TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 05, 2025

We are pleased to announce that Steven Toscher and Philipp Behrendt will be speaking at the upcoming ABA May Meeting being held at the Marriott Marquis, Washington D.C., May 8-10, 2025. The May Tax Meeting is the Section’s largest and the premier event for lawyers interested in all aspects of tax law. Join us in Washington, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 30, 2025

We are pleased to announce that Sebastian Voth and Philipp Behrendt of our firm are participating in the California Lawyers Association – Taxation Section DC Delegation on May 5-7, 2025. For over 30 years, the Taxation Section has annually selected a delegation to present the ideas and proposals of California tax lawyers to officials in […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 29, 2025

We are pleased to announce that Melissa Briggs along with Gary Slavett (Holtz, Slavett & Drabkin, APLC) will be speaking at the upcoming Beverly Hills Bar Association Refund Litigation – Where District Court Differs from Tax Court webinar, Tuesday, May 6, 2025, 12:00 p.m. – 1:30 p.m. (PST). This program focuses on key procedural and strategic differences […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 22, 2025

This article primarily delves into the nuances and lessons learned from the four precedential opinions issued by California’s Office of Tax Appeals (OTA) with respect to the taxation of residents. It also serves as a reminder of the complexity of California’s residency issues and the value of consulting a qualified tax attorney in matters that […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 15, 2025

On March 21, 2025, the Supreme Court handed down a unanimous decision in Thompson v. United States, 604 U.S. ___, a case interpreting 18 USC §1014, making false statements for purposes of influencing certain financial institutions. The defendant in the case is Patrick Thompson. The Court’s opinion does not talk about who Thompson is. He […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 09, 2025

Attorneys from our firm have written extensively about foreign bank account reporting (FBAR) penalties.[1] Fifteen years ago, Steven Toscher and Barbara Lubin raised the specter that willful FBAR penalties could violate the Eighth Amendment’s Excessive Fines Clause in the article When Penalties Are Excessive—The Excessive Fines Clause as a Limitation on the Imposition of the Willful […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 01, 2025

We are pleased to announce that Jonathan Kalinski and Philipp Behrendt along with Jordan Bass (Taxing Cryptocurrency) will be speaking at the upcoming Strafford Taxation of Digital Asset Transactions Under Current Tax Law webinar, Thursday, April 3, 2025, 10:00 a.m. – 11:30 a.m. (PST). This webinar will provide tax counsel and advisers with a detailed analysis of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 21, 2025

We are pleased to announce that Steven Toscher and Michel R. Stein along with William J. Curtis (Polsinelli) will be speaking at the upcoming Strafford IRS Final Regulations for Syndicated Conservation Easements webinar, Thursday, March 27, 2025, 10:00 a.m. – 11:30 a.m. (PST). This course will provide tax counsel and advisers guidance on critical tax issues concerning conservation […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 13, 2025

We are pleased to announce that Sebastian Voth will speak before the Glendale Estate Planning Council on Tuesday, March 18, 2025. His presentation will delve into “audit stage” type issues to consider at the estate planning level, including privilege issues, IRS summons interviews, communications with experts, and preparing for potential Tax Court litigation. Understanding your client’s […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 03, 2025

We are pleased to announce that Cory Stigile had been elected as Fellow of the American College of Tax Counsel. Cory joins seven other members of our firm who are Fellows of the most prestigious group of tax lawyers in the United States. As noted by the President of ACTC, “The new Fellows bring a range of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 28, 2025

We are pleased to announce that Sandra R. Brown along with Caroline Ciraolo (Kostelanetz LLP), Maisha Horton (IRS Criminal Investigations Division), Matthew Mueller (Fogarty Mueller Harris, PLLC) and Rod Rosenstein (King & Spalding) will be speaking on The Long and Winding Road From Civil Fraud Referral to Criminal Tax Indictment at the upcoming ABA Criminal […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 24, 2025

We are pleased to announce that Michel R. Stein and Robert S. Horwitz will be speaking at the upcoming CalCPA Federal and State Residency Issues webinar, Thursday, February 27, 2025, 9:00 a.m. – 10:30 a.m. (PST). This webinar will guide tax professionals and advisers on the latest IRS examination guidance on U.S. residency and California residency […] Read More…