Experienced Tax Court Attorney

Daniel W. Layton has handled hundreds of cases filed in United States Tax Court. His Tax Court litigation, motion practice, and trial experience has resulted in the following opinions, among others:

Joseph E. Abe, DDS, Inc. v. Commissioner, Full Tax Court Opinion at 161 T.C. No. 1.

Castro v. Commissioner, Tax Court Memorandum Opinion at T.C. Memo. 2022-120. The Tax Court found IRC Sec. 6751(b)(1) penalty approval while declining to follow the 9th Circuit's Laidlaw opinion. Notably, this case was cited among IRS-adverse authority on in an April 11, 2023, IRS Notice of Proposed Rulemaking seeking to expand Laidlaw.

Ukattah v. Commissioner, (Tax Court decision following trial, ordering reduction of most of the taxes asserted by the IRS) U.S. Tax Court Docket No. 19361-16

McGrady v. Commissioner, U.S. Tax Court Docket No. 13015-07

Villela-Wilcox v. Commissioner, T.C. Summary Opinion 2009-75

Wilson v. Commissioner, T.C. Memo. 2010-134

Torres v. Commisioner, T.C. Summary Opinion 2009-170

Pacheco v. Commissioner, T.C. Summary Opinion 2007-125

Hough v. Commissioner, T.C. Summary Opinion 2009-14 (pre-trial litigation)

Garza v. Commissioner, T.C. Summary Opinion 2007-29

Coastal Heart Medical Group et al v. Commissioner, T.C. Memo. 2015-84 (Post Trial Briefing)

Jorgensen v. Commissioner, (motion and briefing practice) Order at Docket No. 21936-06 (Full Opinion at T.C. Memo. 2015-84)

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