Orange County Tax Attorney Blog

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Can You Net Gambling Wins With Gambling Losses on Your Tax Return?

Can You Net Gambling Wins With Gambling Losses on Your Tax Return? Taxpayers who gamble casually (meaning they do not qualify as being professional gamblers under […]

Letting the Door Hit You in the Tax on the Way Out: IRS Issues Relief Procedures for Certain Persons Who Relinquished US Citizenship But Wish to Complete Tax Compliance

In September of 2019, the IRS Issued Relief Procedures for Certain Persons Who Relinquished Their United States Citizenship But Who Were Out of Tax Compliance. The […]

What Is the Standard for Admission of Evidence in a Hearing on Revocation of Probation or Supervised Release?

What Is the Standard for Admission of Evidence in a Hearing on Revocation of Supervised Release or Probation? Because the Federal Rules of Evidence do not […]

Murrieta Tax Preparer Gets No Jail Sentence for Tax Crime

A Murrieta return preparer is reported by patch.com (here) to have received a sentence of home detention, probation, and community service, although the sentencing guidelines provided […]

The General Rules Applicable to Federal Interpleader Actions Involving Federal Tax Liens

Interpleader actions are authorized by 28 U.S.C. § 1335 and Rule 22 of the Federal Rules of Civil Procedure where plaintiffs holding funds to property upon […]

Former Head of Foster Agency Sentenced for Theft, Money Laundering, Tax Evasion

The DOJ issued a press release in June highlighting the sentencing, after conviction at jury trial, of an Oregon woman found guilty of stealing over $1 […]

Tax Court Holds IRS Assessment of Trust Fund Recovery Penalty Invalid Where No Final Administrative Determination Issued

In Romano-Murphy v Commissioner, 152 T.C. No. 16 (2019), the United States Tax Court held that an IRS assessment of a Trust Fund Recovery Penalty under […]

US Supreme Court Holds States Cannot Tax Out-of-State Trust Income if Undistributed to In-State Beneficiaries

The Supreme Court Issued Its Opinion in North Carolina Department of Revenue v. Kimberly Rice Kaestner 1992 Family Trust on June 21, 2019. Click here for […]

Can an Unrecorded Deed Defeat an IRS Federal Tax Lien?

Can an Unrecorded Deed Defeat an IRS Federal Tax Lien in California? Yes, an unrecorded deed for California real property can defeat a later-arising IRS federal […]

Author K. Slaughter Found Liable for Employment Taxes, But Not Penalties, in Tax Court Opinion

Author K. Slaughter Found Liable for Employment Taxes, But Not Penalties in U.S. Tax Court Opinion. In K. Slaughter v. Commissioner, T.C. Memo. 2019-65, an opinion […]

Attorney’s Fees in Interpleader Action? Not If It Impairs Recovery of Federal Tax Lien.

Attorney’s Fees in Interpleader Action? Not If It Impairs Recovery of Federal Tax Lien. Can the party filing an interpleader in California recover the costs and […]

Issuing a State Court Subpoena to Federal Officials: Beware the Touhy Doctrine.

Issuing a State Court Subpoena to Federal Officials: Beware the Touhy Doctrine. Can you subpoena an IRS or another Federal official in a state court action? […]

Enforcement of Money Judgments Against Property in Jurisdiction of California Probate Court: The Interaction Between Cal. Code. Civ. Proc. Sections 709.030, 695.010 and 697.310

Enforcement of Money Judgments Against Property in Jurisdiction of California Probate Court: The Interaction Between Cal. Code. Civ. Proc. Sections 709.030, 695.010 and 697.310 One issue […]

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 […]
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