Introduction / Legal Disclaimer
Welcome to the Tax Litigation (Civil & Criminal) Report! This Report is intended solely for tax professionals to share and exchange general (non-client specific) thoughts and comments regarding recent developments, procedures, cases and authorities involving federal tax disputes and the representation of taxpayers before the Internal Revenue Service in examinations, tax collection matters, administrative Appeals, tax litigation, and criminal tax investigations as well as in criminal tax prosecutions by the U.S. Department of Justice.
Discussions may include current IRS enforcement priorities, strategies and iniatives; consideration of various strategies and techniques in the representation of clients involved in tax examinations; voluntary disclosures involving domestic and foreign tax issues; preservation of relevant privileges; considerations re the imposition civil tax penalties; defending potential practitioner penalties and sanctions under the Internal Revenue Code and Circular 230; methods of handling sensitive issue tax-related examinations and criminal tax investigations and prosecutions; federal sentencing considerations, etc.
The Tax Litigation (Civil & Criminal) Report is a publication by HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C. The firm is widely recognized as among the preeminent tax law firms within the United States having an unparreled reputation for excellence and integrity in the federal and state, civil and criminal, tax controversy and tax litigation community. HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C. is highly respected for utilizing every available resource in the successful pursuit of the strategic and tactical objectives of its clients and pursues an innovative approach in its efforts to provide the highest quality legal services available. (www.taxlitigator.com)