Star Q. Lopez

Daniel W. Layton

Elite Law Firm Credentials. Real Government Experience.

Orange County Tax Lawyers Whose Experience Speaks for Itself.

The Orange County-based lawyers at Layton & Lopez Tax Attorneys, LLP, know how the government works because they worked for the government. Mr. Layton and Mrs. Lopez take those insights and use them to the advantage of their clients, helping them navigate pitfalls and traps that their clients may otherwise encounter. Dealing with IRS, California Franchise Tax Board, EDD, or BOE Sales Tax audits, collections, or criminal investigations can be intimidating without experienced attorneys to level the playing field – attorneys who know how the other side works. Our comprehensive tax law practice not only provides competent and aggressive legal defense, but also advice to proactively avoid tax problems.

Ex-IRS Tax Attorney. Ex-Federal Prosecutor.


Daniel 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. Now, as partner in Layton & Lopez, Daniel uses his unique insights to help his clients and keep the IRS in check. Daniel has exceptional knowledge of the tools available to the IRS 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, Daniel’s experience from inside the IRS as an attorney tasked with enforcement and review of FBAR penalties for failure to disclose foreign accounts, tax fraud penalties, and other penalties gives him substantial insights in defending clients from wrongful and aggressive IRS tax investigations and collections.

Estate Planning Attorney and Tax Attorney with an International Law Focus.


Tax and estate planning attorney Star Lopez brings years of elite law firm and government experience to the firm. After graduating from UCLA School of Law in 2007, Star began her career as a real estate associate in the Costa Mesa office of Rutan & Tucker, LLP, where she worked on a variety of business matters, including drafting agreements for a Fortune 500 company. She followed her corporate legal experience with nearly 6 years in patriotic public service, serving as a Judge Advocate in the United States Air Force, where she attained the rank of Captain and was awarded a Joint Service Commendation Medal in 2013.

In addition to handling a variety of tax law matters, partner Star Lopez manages the firm’s business planning and estate planning practices. Star’s unique education and professional background, including advanced degrees from the esteemed University of Chicago Booth School of Business and NYU’s tax law program, allows her to provide comprehensive high-quality guidance to her clients. Most importantly, she holds a deep concern for her clients’ well-being. Star guides families, companies, and entrepreneurs in achieving their professional and personal objectives by tailoring her advice and planning to each of their unique concerns.

Elite Law Firm Credentials. Valuable Government Experience.


Sam Layton is Special Counsel with the firm and works primarily on federal tax controversies before the IRS. After graduating from Harvard Law School, Sam worked in a prestigious United States District Court clerkship, working directly under a federal district court trial judge. Following the clerkship, he worked in a litigation section of a large Orange County firm.

With over 20 years of combined legal experience, Layton & Lopez Tax Attorneys, LLP provides its clients with the highest standard of representation in their tax matters, including audit, collections, and criminal tax defense as well as tax, business, and estate planning.

Recent Article Highlight: What is the maximum FBAR penalty? Two U.S. District Courts say $100,000, but one Court of Federal Claims judge disagrees..

Posted 08/04/2018, By Daniel W. Layton: Two Federal District Court judges have held that 31 C.F.R. 1010.820, a preexisting regulation limiting the maximum willful FBAR penalty to $100,000, remained effective and restricted the ability of the IRS to impose a higher penalty which would otherwise be allowed by a later-revised statute. However, in a recent Court of Federal Claims opinion another judge has held the preexisting regulation is invalid as it was not updated since the statutory revision. Notably, while the initial regulation preceded the statutory change, the regulation’s upper limit was extended regularly to account for inflation and, thus, reaffirmed by the treasury since the statutory change. Also, the treasury clearly has discretion within the statutory range to impose what the department sees as reasonable, and the statutory maximum does not ever have to be imposed if the treasury determines that circumstances would never require it. While a regulation requiring more than the statutory maximum FBAR willfulness penalty would be in conflict with the statute, there is a serious question about whether the regulation and the statute truly conflict... Click here for more.