STEVEN TOSCHER Quoted in Tax Notes
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, July 12, 2023
“A criminal case based on a substantively debatable return position could be legally stillborn, he said . . . The IRS and Justice Department shouldn’t be prosecuting cases turning on unclear law, Toscher said . . . This Supreme Court would likely be amenable to conviction challenges if the agencies managed to convict someone for taking a position on which the law is uncertain, he said . . . The need for the competent authority agreement clarification will likely bolster that defense, according to Toscher.”
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