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Our Publications

Where’s Waldo? The IRS’s Search for High-Income Non-Filers
Robert Horwitz
Sandra Brown

Journal of Tax Practice and Procedure Fall, 2021

The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes
Robert Horwitz

Journal of Tax Practice and Procedure Spring, 2021

What Makes a Failure to File Your Tax Returns a Felony?
Sandra Brown

Journal of Tax Practice and Procedure Fall 2020

IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office
Steven Toscher
Sandra Brown
Lacey Strachan

Los Angeles Lawyer June, 2020

The New Independent Office of Appeals Must Be Independent to Survive
Steven Toscher
Jonathan Kalinski
Gary Markarian

Journal of Tax Practice and Procedure Summer, 2020

UCLA 35th Annual Tax Controversy Conference – Message from Steven Toscher, Institute Chair
Steven Toscher

Journal of Tax Practice and Procedure April, 2020

Utilising the IRS Streamlined Compliance Programme to Manage US Tax Risk
Steven Toscher , Michel Stein and Sandra Brown

Financier March, 2020

Taxpayers First
Steven Toscher, Robert Horwitz and Gary Markarian

Los Angeles Lawyer December, 2019

The Impact of “Big Data” on IRS Civil and Criminal Tax Enforcement
Steven Toscher
Daniel Kellerman

Los Angeles Lawyer July - August, 2019

Important Developments: Criminal
Evan Davis
Sara Neill

ABA Tax Section Criminal and Civil Tax Penalties Committee May Meeting 2019 May, 2019

Now I Am a C Corp: What About the Accumulated Earnings Tax?
Cory J. Stigile

Tax Notes Today April 15, 2019

Can the IRS Assess or Collect Foreign Information Reporting Penalties?
Robert Horwitz

Tax Notes January, 2019

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