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).