TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

I am very pleased to announce this year’s ABA National Institute on Criminal Tax Fraud & Tax Controversy to be held December 12-14, 2022 at Caesar’s Palace in Las Vegas, Nevada. I am honored again to be serving as Co-Chair with Kathryn Keneally. We look forward to the best programs in the nation on civil and criminal tax controversy and litigation and well—Las Vegas. 

Go online to the following link below. We are able to offer a 20% discount for friends of our firm. If you are signing up, please contact Sharon Tanaka at sht@taxlitigator.com for the discount code.

Click Here to Register

We have an amazing line up of speakers and panels this year including —

Tax Court Judge Mark V. Holmes and former IRS Chief Counsel Michael Desmond will be on a panel discussing recent Supreme Court decisions and the changes to the tax litigation landscape caused by application of the Administrative Procedure Act.

IRS Deputy Chief Counsel for Operations Drita Tonuzi and Tax Division Southwestern Section Chief Cynthia Messersmith will be discussing IRS and Department of Justice civil enforcement priorities.

The National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy, combined together in one event, comprises the yearly gathering of the criminal tax controversy and criminal tax defense bar. The program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense. 

I am very pleased that members of our firm will be participating in the following panel presentations:

Steven Toscher
What the IRS Enforcement Will Look Like in the Future

Edward Robbins, Jr.
Lacey Strachan
Criminal Tax Workshop

Sandra Brown
Criminal Enforcement Priorities

Michel Stein
BBA Partnership Examinations – Problems and Opportunities

Evan Davis
The Benefits and Burdens of Plea Agreements

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming Los Angeles Estate Planning Council seminar “Lawyers, Guns & Cryptocurrency,” Wednesday, November 16, 2022, 11:45 a.m. – 1:30 p.m. (PST) at the The California Club (538 S Flower St, Los Angeles, CA 90071).

This seminar will address the challenges of administering estates that contain the unusual assets of cryptocurrency and other digital assets, and firearms, and how estate planners can better anticipate and prepare for these challenges. 

Click Here for more information.

Sandra Brown was recently quoted in Forbes on the recent decision in Green Valley Investors, LLC v. Commissioner, 159 T.C. No. 5 (November 9, 2022), where the United  States Tax Court invalidated IRS Notice 2017-10, pertaining to the listing and reporting requirements for syndicated  conservation easements.  

Check out the great article–“IRS Loses Battle in War on Conservation Easements” authored by Guinevere Moore in Forbes at the following link: https://www.forbes.com/sites/irswatch/2022/11/10/irs-loses-battle-in-war-on-conservation-easements/amp/

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.

We are very pleased to report that the 38th Annual UCLA Extension Tax Controversy Institute which took place on October 27 at the Beverly Hills Hotel was a resounding success. After two years of video conferences, the annual gathering of top Government representatives and private practitioners was back in person and in full force. 

We want to thank the great staff of UCLA Extension, our sponsors, our special out of town guests and all the panel participants for making this the best Institute ever. 

A special shout out to our friends at the IRS for their assistance in putting together the program. The panel programs this year were outstanding. With Keynote presentations from the Taxpayer Advocate- Erin Collins, the Chief of Criminal Investigation- Jim Lee and Deputy Commissioner, SBSE Collection & Operations Support- Darren Guillot, and the IRS Commissioner Charles “Chuck” P. Rettig, the program had to be a success. The program can be found at the following link:

Click Here for the Program

There is so much more to say about the program and the great panels, but for this post let us conclude with another congratulations to both Paula M. Junghans, this year’s recipient of the Bruce I. Hochman Award, and to Charles P. Rettig, our retiring IRS Commissioner, who received the Chillin and Grillin Award which is given each year to a retiring IRS employee. For those who were in attendance, you know how deserving and special the recognition was for both honorees

Thank you all for making this year’s Institute the best ever. 

Steven Toscher and Sandra Brown, Co-Chairs
UCLA Extension Tax Controversy Institute

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Spidell webinar “Cryptocurrency Tax Compliance in the Rollercoaster Bitcoin World,” Tuesday, November 15, 2022, 10:00 a.m. – 12:00 p.m. (PST).

This course will provide tax counsel, accountants, and other advisers with a critical first look at recent IRS enforcement actions on taxpayer compliance and reporting obligations for cryptocurrency transactions. The panel will discuss the IRS position on the tax treatment of cryptocurrency, analyze IRS monitoring to increase compliance, consider criminal investigations and prosecutions for failing to report crypto transactions accurately. The panel will define proper reporting and tax treatment for “mining” and exchanging cryptocurrency along with tactics in managing IRS examinations and audits.

Click Here for more information.

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