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Yes, You Actually Can Go to Jail for Not Paying Taxes

YES, YOU ACTUALLY CAN GO TO JAIL FOR NOT PAYING TAXES

Cost Free
Presentation Length 1.0 hour

Recorded DateNovember 18, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

In recent years, pursuing criminal tax cases involving a taxpayer’s interference with the collection of tax debts has gained increasing favor with the IRS Criminal Investigation.  Attendees will learn about current trends in tax prosecutions focused on “evasion of payment” under 26 U.S.C. Section 7201 and the “willful failure to collect, pay over, or truthfully account for a tax” under 26 U.S.C. Section 7202, and learn how statements your client makes on an IRS Form 433 or Form 4180 may end up as the Government’s Exhibit 1 in a criminal case.

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Steven Toscher is a principal of Hochman, Salkin, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.

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Before joining the firm as a principal, Sandra Brown spent more than 26 years as a federal trial lawyer, including serving as the Acting United States Attorney and twice as the First Assistant United States Attorney, in the Office of the U.S. Attorney, Central District of California. In addition to leading the Central District of California’s United States Attorney’s Office, where she supervised approximately 270 attorneys in the largest Justice Department Office outside of Washington, D.C. Ms. Brown also served as the Chief of the Tax Division for more than ten years where she supervised lawyers within the United States Attorney’s Office, the Department of Justice Tax Division and the Department of Treasury who were responsible for complex Federal civil and criminal tax matters, including related grand jury proceedings, trials, and appeals. 

Ms. Brown’s broad range of experience in complex civil tax controversies and criminal tax investigations and litigation includes having handled over 2,000 cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the California Superior Court.  She obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax counsel as well as a member of the California State Bar, American Bar Association Tax Section & Criminal Justice Section, NYU Tax Controversy Institute Advisory Committee, Beverly Hills Bar Association Taxation Section, Federal Bar Association, California Lawyers Association Tax Section, and the Women’s White Collar Defense Association.    

Ms. Brown’s practice focuses on 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.

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Robert Horwitz has over 35 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 the 2015-2016 year.  He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Before entering private practice, Mr. Horwitz was a trial attorney in the U.S. Department of Justice Tax Division and the U.S. Attorney’s Office in Los Angeles, where he represented the United States in several hundred tax cases, involving areas as diverse as captive insurance companies, tax shelters, trust fund recovery penalties, manufacturers’ excise taxes, employment taxes, criminal investigations, and tax collection. At the Department, Mr. Horwitz received numerous awards, including two Outstanding Trial Attorney awards and a Special Commendation from the Tax Division.

Mr. Horwitz has also represented clients in complex civil and white-collar criminal cases, including civil and criminal bank fraud, wind and thermal energy tax shelters, tax fraud and tax collection matters, trademark, trade secrets, securities, and insurance coverage cases. He was also appointed by the United States District Court in Los Angeles to represent a death row inmate in habeas corpus proceedings.

Mr. Horwitz has been a speaker on tax matters at the UCLA Tax Controversy Institute, the Annual Meeting of the Taxation Section of the California Bar, and the California State Bar Annual Meeting. He has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the Federal Lawyer (the publication of the Federal Bar Association), and the California Tax Lawyer.  His monograph in “Responsible Persons and Fiduciary Liability” was published in the Proceedings of the New York University 75th Institute on Federal Taxation.  He was an invited delegate to the 2015 U.S. Tax Court Judicial Conference.  He is a member of the Planning Committee of the UCLA Tax Controversy Institute.

Mr. Horwitz is a member of the bar in California and in Illinois. He is admitted to practice in the United States District Courts for the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018.

About Our Presenter

Hochmansalkintoscherperez
HOCHMAN, SALKIN, TOSCHER & PEREZ, P.C., enjoys an unparalleled reputation for excellence and integrity in the tax community. For more than 60 years, the firm has been serving clients throughout the United States with federal and state civil tax litigation, defense of criminal tax prosecutions, all forms of tax disputes with the federal, state and local taxing authorities, white collar criminal defense, estate and business planning, and business transactions.