TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 05, 2023

The Internal Revenue Service has long had the power to issue and enforce administrative summonses for the purpose of “ascertaining the correctness of any return … determining the liability of any person for any internal revenue tax … or to collect any such liability.” See Reisman v. Caplin, 375 U.S. 440 (1964). While the courts and the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, July 02, 2023

IRS Special Agents fanned out throughout the United States on June 30, seeking to interview promoters and clients of a “Maltese individual retirement arrangement” that for the past three years has earned a spot on the IRS’s Dirty Dozen tax promotions list. These are simply the first public actions in what will doubtless be a massive […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 22, 2023

We are pleased to announce that Michel Stein along with Caroline Ciraolo, Phillip Colasanto and Daniel Price will be speaking at the upcoming CPA Academy webinar “The Future of Voluntary Disclosures: Coming in From the Cold,“ Wednesday, June 28, 2023, 9:00 a.m. – 10:00 a.m. (PST). For more than 70 years, the IRS maintained a voluntary […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 21, 2023

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Robert Horwitz will be speaking at the upcoming Strafford webinar “Foreign Information Return Penalties After Farhy: Case Review and Updates, Penalty Abatements, Refund Claims,“ Tuesday, June 27, 2023, 10:00 a.m. – 11:50 a.m. (PST). The Supreme Court, in Bittner v. United States, limited the imposition […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 16, 2023

We are pleased to announce that Robert Horwitz, Cory Stigile and Philipp Behrendt will be speaking at the upcoming Strafford webinar “Partnership Losses in Excess of Basis: Preparing for the IRS Audit Campaign,“ Tuesday, June 20, 2023, 10:00 a.m. – 11:50 p.m. (PST). In February 2022, the IRS announced a partnership campaign to include audits of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 14, 2023

I am very pleased to announce and ask you to Save the Date for this years ABA National Institute on Criminal Tax Fraud & Tax Controversy to be held December 7-9, 2023 at Wynn, Encore in Las Vegas, Nevada. I am honored again to be serving as Co-Chair with Kathryn Keneally. We look forward to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 12, 2023

HOCHMAN SALKIN TOSCHER PEREZ P.C. is proud to be recognized by Chambers and Partners as one of only three top tier law firms in its U.S. 2023 High Net Worth Guide in the category of Tax: Private Client, as well as a top firm nationwide in the Tax Controversy and Tax Fraud areas. Chambers concluded that […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 06, 2023

We are pleased to announce that Steven Toscher and Evan Davis will be speaking at the upcoming CalCPA webinar “Defending Civil Fraud Case in light of the new IRS Office of Civil Fraud 2023,“ Tuesday, June 13, 2023, 9:00 a.m. – 10:00 a.m. (PST). In September 2020, the IRS created the Office of Fraud Enforcement (OFE) […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 05, 2023

The FTB issued Notice 2023-02 (Notice) on May 31, 2023 providing taxpayers a time-limited opportunity to resolve tax matters relating to potentially abusive Micro-captive Insurance (MCI) and Syndicated Conservation Easement (SCE) Transactions in return for zero or reduced penalties.   Click Here for Full Article

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 01, 2023

We are very pleased to announce that on May 18, 2023, following the success of the firm’s participation in the Taxation Section of the California Lawyers Association’s “DC Delegation,” the following principals and associates of Hochman Salkin Toscher Perez P.C. were sworn in as members of the Supreme Court of the United States by Chief […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 31, 2023

We are pleased to announce that Dennis Perez, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CPA Academy webinar “Resolving Employment Tax Disputes,” Tuesday, June 6, 2023, 2:00 p.m. – 3:00 p.m. (PST). The IRS is increasing civil and criminal enforcement against taxpayers who fail to comply with withholding and remitting of employment […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 30, 2023

An amendment to the U.S. Sentencing Guidelines Manual that takes effect November 1 will include a new two-level reduction for true first offenders having their first contact with the criminal justice system. The amendment, subject to certain exceptions, will apply to offenders with no criminal history points, including offenders with no prior convictions. In adopting this […] Read More…