Ex-IRS Tax Attorney. Ex-Federal Prosecutor.

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.

A Proven and Experienced Tax Attorney.

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.

Mr. Layton's clients benefit from his experience and reputation at all stages of IRS and FTB investigations, with most cases resolving without the need for defending or prosecuting claims in court. At the administrative levels, Mr. Layton has convinced the IRS and FTB to drop fraud penalties and other penalties, to reduce or eliminate proposed taxes, or issue refunds where the facts and law justified results for his clients - even after other tax professionals failed. In other cases, Mr. Layton uses his experience to help his clients employ strategies to avoid making more costly mistakes or avoid throwing good money after bad.