Orange County Tax Attorney Blog

Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government

In tax cases, the IRS and Department of Justice will generally prosecute cases under Title 26, the Internal Revenue Code. However, if a false statement is […]

Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute

What is the Federal Insolvency Statute? Where the delinquent taxpayer is insolvent but has not filed a petition in bankruptcy, the IRS’ prior right to payment […]
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Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF

On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 […]

When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien?

When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien? Judicial discretion to decline foreclosure in Federal […]
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Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens

Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens California’s Homestead exemption is found in Chapter 4 of Division […]
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Does Res Judicata Apply to Stipulated Tax Court Decisions?

Does Res Judicata Apply to Stipulated U.S. Tax Court Decisions? The judicial principle of res judicata applies to stipulated Tax Court Decisions. However, if the stipulated […]

U.S. Senate Committee Declines to Change DOJ Medical Marijuana Policy

  In August of 2013, the Justice Department announced a marijuana enforcement policy which still endures, at least for the time being.  That “medical marijuana” policy […]
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Rap Star DMX Arrested Under Tax Fraud Charges – Tax Evasion and Failure to File Returns

  Tip of the hat to the Billboard.com’s article for bringing this music industry tax news to my attention.  A recent DOJ press release is reporting […]

Forbes Lists Master’s of Taxation Among 10 Worst Master’s Degrees

  An article on the Forbes.com website providing rankings of the ten best and ten worst master’s degrees (of only 45 popular degrees) has listed the […]

Measure M Los Angeles County Sales Tax Rate Increase as of July 1, 2017

  With over a 70% favorable vote, Measure M passed in Los Angeles County in November of last year.  Per LA Metro’s webpage voters were asked to […]

Introducing the California Department of Tax and Fee Administration and the Office of Tax Appeals

  On June 15th, Senate Bill (SB) 86 was passed.  The bill was called the “Taxpayer Transparency and Fairness Act,” and the full text can be […]

Ranking the Top Tax LLM Programs: Part 3.2 of Is a Tax LLM a Good Idea? [2019 Update]

Tax LLM Rankings. I last posted about the top Master of Laws in Taxation programs about four years ago.  Really, not much can change in that […]

Why is Golden Gate University’s MST (Master’s of Science in Taxation) Program So Well Known?

Golden Gate University has its main campus in San Francisco. But, Golden Gate University also has the most popular, based on my anecdotal observations, Master’s of […]

Motorcycle Racing Business Owner Pleads to Tax Fraud

  Per a recent DOJ press release (which can be seen by clicking here) Dan Kyle, owner of Kyle Racing in Sand City, CA, pleaded guilty […]

Austin v. Commissioner, T.C. Memo. 2017-69

The Untied States Tax Court issued its opinion in Austin v. Commissioner, T.C. Memo. 2017-69, on April 24, 2017.  The full text of the opinion is […]

Northern California Thai Restaurant Owner Sentenced for Underpaying Undocumented Workers and Tax Fraud

  Paying undocumented workers under the table or having off-the-books cash employees often goes hand in hand with tax charges.  The connection arises like a domino […]