California Tax Attorney Since 2005.
Former I.R.S. Trial Attorney.
Ex-Federal Tax Prosecutor.

Daniel W. Layton, Esq.

Skillful and Competent Tax Defense.

Tax Attorneys in Orange County - Newport Beach & Fullerton Offices

Daniel W. Layton is a tax attorney in Orange County, with offices in Newport Beach and Fullerton, California. Mr. Layton founded a tax law boutique to use his experience as an ex-IRS attorney, ex-federal prosecutor, and counsel in a Vault 100 national law firm, to level the playing field for his Orange County clients. Counsel with the firm, Newport Beach bankruptcy attorney Tamar Terzian has over 12 years of experience in complex bankruptcy litigation and is a former trial attorney for the Los Angeles U.S. Attorney's Office with special experience in tax discharge issues. Whether it is an IRS audit, FTB, EDD, or sales/use tax matters, liens or levies, a criminal tax investigation, or a bankruptcy, choosing the right attorney can be a critical step in protecting your rights and your business. In the words of some of our clients:*
"As in-house counsel, I have to deal often with outside counsel. Some are not so good about communicating the status of the case or what the strategy should be in light of new events. Mr. Layton, however, was exceptional.... I did not have to worry that my case was being handled in a competent manner...." PS [Avvo.com].

"...I found 3 attorneys, made contact with all three, and settled on Daniel because of his professional experience, academic background, his highly professional interpersonal skills which allowed him to understand very quickly the predicament I was in and swiftly take actions to stop collections. ...Quite frankly Daniels work saved my retirement and was I felt 'life saving.'..." AMF [Google Local].

"...Daniel Layton was our main client contact, and he worked very closely with us. We did everything he told us to do, and we were able to reach a reasonable agreement with the IRS. We tried two other law firms before them, which resulted in wasted money...." KG [Google Local].

"Mr. Layton is an exceptional tax attorney that resolved problems that 3 so-called CPA's couldn't, with just a simple letter. Exceptional tax attorney." DR [Google Local]

"For many years we we had been searching for a competent attorney to assist us in getting some form of resolution to a tax issue we were facing. Daniel Layton came highly recommended from many individuals within our community. ...our outcome exceeded our expectations." GR [Yelp]
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Ex-Federal Prosecutor & Ex-IRS Tax Attorney in Orange County

Starting his tax controversy career in 2005, tax attorney Daniel W. Layton worked for the IRS as a tax trial attorney and for the Department of Justice as a criminal tax prosecutor for the better part of a decade. As founder of a tax law firm in 2014, Mr. Layton zealously defends his clients using his unique insights to keep the IRS and the California Franchise Tax Board in check. Mr. Layton has exceptional knowledge of the tools available to the IRS and FTB in audits, collections, and criminal tax investigations, and of their legal limits, having trained the IRS’s agents and officers in how to do their jobs. In addition, Mr. Layton's knowledge of what goes on behind closed government doors enables him to anticipate the IRS's next steps and develop a strategy to combat or avoid wrongful and over-aggressive IRS actions.

Mr. Layton earned his law degree at the University of Chicago and his graduate tax law degree in San Francisco and worked in the government for the better part of a decade. But, meaningful experience is more than just résumé lines. Many tax attorneys' experience stops short of trial because they settle virtually every case, which may embolden the government to force an unfavorable settlement. Mr. Layton has trial experience in criminal and civil fraud cases, innocent spouse cases, imputed income cases, business deduction cases, real estate income and expense cases, and beyond. Mr. Layton has also successfully defended and resolved a litany of cases through motion-work. His work in U.S. Tax Court and U.S. District Court has resulted in over 30 reported opinions and more than 100 cases resolved by motion, trial, or stipulated decision ranging from full grants of innocent spouse relief to a money judgment of over 250 million dollars.

CSED - IRS Collection Statute Expiration Date (Tax Article Feature)

What is CSED? CSED is the IRS acronym for Collection Statute Expiration Date as it appears in many IRS internal computer transcripts of taxpayer accounts, which tells the IRS collections officer what the IRS system has computed as the statutory expiration date for collection of the tax. Although the computer's CSED date is sometimes inaccurate, it is still generally relied on by IRS employees in practice. The general rule is that the IRS must collect taxes within 10 years of the date of assessment. The assessment date is the date of the filing of the return (or 4/15 if later) or the date audit/exam liabilities are entered as assessments in the IRS’s records. Some common actions extending the IRS’s time to collect include Requests for IRS Installment Agreement or Payment Plan, requesting an Offer in Compromise (via Form 656)), requesting a Collection Due Process Hearing, or filing Bankruptcy. Certain actions extending the collections period are discussed in this article (click here to continue reading).

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Newport Beach and Orange County Bankruptcy Attorney with Special Tax Experience

Counsel with the firm, Tamar Terzian is a bankruptcy attorney with unique experience in litigating the discharge of federal tax and state tax liabilities. Mrs. Terzian's prior experience includes working as a trial attorney in the Tax Division of the Los Angeles federal prosecutor's office and as a judicial law clerk in United States Bankruptcy Court for the Central District of California. From her time in government and private practice, she has earned a reputation in bankruptcy courts throughout Orange County, Los Angeles, and Riverside as a competent, zealous, and sophisticated lawyer. Mrs. Terzian has represented a variety of clients ranging from small business owners to large companies with over $100 million in assets.

Recent Tax Law Articles and Blog Posts:

FAQ updated on 04/04/2020 by Daniel W. Layton: What is Foregone Interest? Definition and examples.

FAQ by Daniel W. Layton: Tax LLM Rankings: Top 10 Best LLM Programs 2020.

FAQ by Daniel W. Layton: National Standards (IRS).

Blog post by Daniel W. Layton: What You Need to Know About IRS Corona Virus Relief.

Blog post by Daniel W. Layton: Can You Request Audit Reconsideration for an Employment/Payroll Tax Audit?

DOJ Criminal Tax Activity Report by Benjamin Tu: A Palm Beach County Tax Return Preparer was Sentenced to Prison for Filing False Returns and Theft of Government Funds.

Blog post by attorney Daniel W. Layton: Can you be held responsible by the CDTFA for the unpaid sales tax of your employer’s company or of the company you own? The Dual Liability Provisions for a Responsible Person under California Sales Tax Law.

By Daniel W. Layton (Satire): The IRS’s Laguna Niguel Office – Where IRS Tax Attorneys, Revenue Agents, and Criminal Special Agents Work.
With offices in Newport Beach and Fullerton, our tax attorney firm serves Orange County, CA, cities including, Irvine, Laguna Niguel, Mission Viejo, Laguna Beach, San Juan Capistrano, Lake Forest, Costa Mesa, and San Clemente and other Southern California cities, in the areas of IRS, FTB, EDD, sales tax, and use tax and bankruptcy.

*Client reviews are the opinions of the individuals and are not representations by this law firm with respect to future results. Results in all cases vary depending on the individual facts and circumstances. The American Society of Legal Advocates is an independent legal organization. The selection process for the ASLA Top 100 Lawyers and membership may be found at https://societyoflegaladvocates.org/selection-process/.
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