Posted by: Steven Toscher | October 28, 2022


We are very pleased to announce that our friend and partner Robert Horwitz has been recognized for his outstanding contributions in the field of taxation by the California Lawyers Association 2022 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2-4, 2022.

Robert has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Sandra Brown, Evan Davis and Jonathan Kalinski will also be speaking on the following topics:

Criminal Tax Bootcamp – How to Represent

Clients in Criminal Tax Matters

In re Grand Jury and the Impact on Dual-Purpose

Attorney Client Privilege

Responsible Persons Liability

Click Here for more information.

We are pleased to announce that Steven Toscher, Sandra Brown and Michel Stein will be speaking at the upcoming NBI webinar “IRS Enforcement Priorities Update (Under the Inflation Reduction Act),” Thursday, November 17, 2022, 9:00 a.m. – 10:00 a.m. (PST).

The Inflation Reduction Act of 2022 (IRA) increased the IRS’s budget by almost $80 billion over the next 10 years, and with half of that money earmarked for tax enforcement, tax practitioners can expect that IRS examinations of high-income clients will ramp up. This legal tax guide offers clear guidance we have so far on the current IRS priorities and on the way individuals, businesses, trusts, and estates can shore up compliance and become better prepared for more likely audits.

  • Stay informed of recent guidance from the IRS.
  • Get up to speed on emerging case law developments.
  • Help clients prepare for the coming audit trends.

Click Here for more information..

We are pleased to announce that Steven Toscher, Robert Horwitz and Lacey Strachan will be speaking at the upcoming Spidell webinar “Estate and Gift Tax Audits,” Monday, November 7, 2022, 10:00 a.m. – 12:00 p.m. (PST).

Practical advice for preparing for and resolving estate and gift tax issues with the IRS. Topics covered include:

  • Preparing an estate or gift tax return with an eye toward litigation
  • Handling an IRS examination
  • Settling estate and gift tax cases with the IRS Appeals Office
  • Litigating estate tax and gift cases in Tax Court

Click Here for more information.

We are pleased to announce that Edward Robbins, Jr. and Evan Davis will be speaking on the following topics at the upcoming Hawaii Tax Institute 59th Annual In-Person Conference being held at the Sheraton Waikiki, November 6-10, 2022.

Edward Robbins, Jr.
November 9, 2022
“FBAR Reporting: Trends, Pitfalls, and Enforcement. What You Need to Discuss With Your Clients”

Evan Davis
November 10, 2022
“When Aggressive Tax Planning Becomes Criminal Conduct and Ethical Considerations”

Click Here for more information

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Sandra Brown will be speaking at the upcoming Spidell webinar “Form 8300 Reporting/Cash Intensive Business Audits,” Friday, October 21, 2022, 10:00 a.m. – 12:00 p.m. (PST).

The law requires that trades and businesses report cash payments of more than $10,000 to the federal government by filing Form 8300. This course will explain the Form 8300 filing obligations of those accepting cash payments in their businesses, best practices surrounding the filing of Form 8300, the current civil and criminal enforcement environment surrounding Form 8300 non-compliance, and the voluntary disclosure and mitigation practices surrounding the non-compliant. Do not be caught unprepared! 

Click Here for more information.

It was a long-held belief that the Anti-Injunction Act barred taxpayers from maintaining any lawsuit that had the effect of interfering with the assessment or collection of any tax. However, the recent Supreme Court decision in CIC Services created a crack in the Government’s use of the Anti-Injunction Act to dismiss cases for lack of subject matter jurisdiction. The First Circuit, relying on the holding in CIC Services, LLC v. IRS, has now, in its ruling in Harper v. Rettig, further widened that crack.

Click Here for full article.

Sandra R. Brown is a Principal at Hochman Salkin Toscher Perez P.C., and former Acting United States Attorney, First Assistant United States Attorney, and the Chief of the Tax Division of the Office of the U.S. Attorney (C.D. Cal). Ms. Brown specializes in representing individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court. 

Gary Markarian is an Associate Attorney at Hochman Salkin Toscher Perez P.C., and a graduate of the joint JD/LL.M. Taxation program at Loyola Law School, Los Angeles. While in law school, Mr. Markarian served as an intern at the Tax Division of the U.S. Attorney’s Office (C.D. Cal) and Internal Revenue Service Office of Chief Counsel’s Large Business and International Division.

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman webinar “FBAR: Current Legal Developments and Challenges,” Thursday, October 20, 2022, 1:10 p.m. – 2:00 p.m. (CST).

The Supreme Court has finally granted certiorari to look at the non-willful FBAR penalties imposed by the IRS. Originally enacted in the 1970s, the Bank Secrecy Act’s FBAR provisions have more recently become a prominent source of penalties associated with failures to report foreign accounts.  This panel of experts will discuss the FBAR and related penalty considerations, as well as caselaw development and the prospective challenges and potential implications of a Supreme Court decision in the area. 

Click Here for more information.

We are pleased to announce that Michel Stein and Sandra Brown will be speaking on the following topics at the upcoming 81st Institute on Federal Taxation being held at the Westin New York, October 23-28, 2022 and Hotel Del Coronado, November 13-18, 2022.

Sandra Brown
October 23, 2022 and November 13, 2022
“Tax Controversies”

Michel Stein
November 17, 2022
” When Are You Crossing a Line? Real Life Ethical Issues in Everyday Tax Practice”

Click Here for more information.

We are pleased to announce that Michel Stein , Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Partnership Audit Adjustments Under the Centralized Audit Regime,” Wednesday, October 19, 2022, 10:00 a.m. – 11:30 a.m. (PST).

This course will cover practical considerations for partners and advisers to partnerships operating under the new partnership audit regime. Our panel of experts will review the latest guidance, explain partnership audit adjustments, and recommend steps to implement this reporting regime.

IRS audits are taking place under the Bipartisan Budget Act’s new audit regime, and tax professionals are wrestling with the complexities of the new requirements. Under these rules, the partnership itself remits any underpayment resulting from an IRS examination at the end of an IRS review. It pays the additional tax due at the highest income tax rate (37 percent currently).

Alternatives include making a push-out election taxing the individual partners’ interests during the year examined and showing that partners have amended their returns to account for the adjustments. The Corrections Act in 2018 reduced the burden of filing amended returns by allowing partners to pay the amount of tax due and adjust any related tax attributes without the limitation of filing amended tax returns, the pull-in procedure.

The reporting regime includes Form 8986, Partner’s Share of Adjustments to Partnership-Related Items, and Form 8978, Partner’s Additional Reporting Year Tax. Partners receiving Form 8986 must file Form 8978 to report additional tax due as a result of examination adjustments. Multiple forms may be obtained, covering changes for different years, and these adjustments could be both negative and positive.

The rules are so complex that the AICPA recommended a new form AAR-EZ to simplify the reporting process.

Listen as our panel of experts explains the ins and outs of audits under BBA, including making push-out and pull-in adjustments, electing out, and best practices for handling the audit.

We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at 

Click Here for more information.

Posted by: Steven Toscher | October 6, 2022

UCLA 38th Annual Tax Controversy Conference – October 27, 2022

We are pleased to let you know that the planning for the 38th Annual UCLA Extension Tax Controversy Institute is proceeding and we have an exceptional program lined up with top governmental officials and leading private practitioners from around the country. 

As you know the Institute is back in person this year after two years Covid/Zoom protocols and we are all excited to see old and new friends in person. 

Click Here to Register

We have had amazing sponsors of the program and we encourage those who have sponsored in the past to join us again and we always welcome new sponsors. Go to the following link for sponsorship information.

Click Here for Sponsorship Information

Now, for the Highlights –

  • The Commissioner of Internal Revenue – Charles P. Rettig – will present a luncheon keynote on the state of Internal Revenue Service. 
  • The Taxpayer Advocate – Erin Collins – will present a breakfast keynote on what the Taxpayer Advocate Service is doing to assist taxpayers and tax administration.  
  • Darren J. Guillot – Deputy Commissioner, Operations and Collection, SB/SE – will present an afternoon keynote on “What IRS Collection Will Look Like Over the Next 10 Years”. 

In addition to these keynotes, we will hold the following panel presentations –

Employment Tax: Employee Retention Credits: “What’s Old Is New Again: IRS’s Renewed Focus on Employee

Tax Compliance Issues”

R&D Credits: “If You Build It, They Will Come…The Taxing Authorities Focus on R&D Credits”

How To Resolve Your Cases at IRS Appeals Including Cases Docketed Before the Tax Court

Crypto Compliance & Enforcement

Collection & Offer Specialist Panel & An IRS Campaign

BSA & F8300 Compliance

Criminal Tax Enforcement

Click Here for more information

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