Orange County Tax Attorney Blog

How Long Do You Have to File a Franchise Tax Board Tax Refund Suit?

Question: How Long Do You Have to File a California Franchise Tax Board Income Tax Refund Suit? Answer: Generally, if you have full paid the tax […]

Recent Conviction Illustrates Connection Between Use of Nominees and Tax Evasion

A Recent Conviction in Hawaii’s U.S. District Court Illustrates How the Use of Nominees Can Put You in the Crosshairs of the IRS and DOJ for […]

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 […]

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 […]
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What Is a Federal IRS Tax Lien?

What is a federal IRS tax lien? A federal IRS tax lien is a lien for unpaid tax liabilities which arises in favor of the United […]
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What Is an IRS Tax Assessment?

What Is an IRS Tax Assessment? An IRS tax assessment is a bookkeeping entry made by the Internal Revenue Service when an IRS assessment officer signs […]
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I Quit My Federal Prosecutor Job Because of a Government Shutdown

I Quit My Federal Prosecutor Job Because of a Government Shutdown: My Story. When I was offered a line-attorney job at the U.S. Attorney’s Office for […]

The IRS’s Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work

The IRS’s Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work If you have ever been to the “Ziggurat,” you never […]

Kimble v. United States, Court of Claims No. 17-421 – FBAR Willfulness Penalty Case

The below is the HTML text of the original opinion in the Kimble v. United States opinion in the United States Court of Claims, a wilful […]
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Bedrosian v. United States – FBAR Wilfullness Penalty Standard Considered by Third Circuit Court of Appeals

Recent Tax Opinion Highlight: The opinion of United States Court of Appeals for the 3rd Circuit in Arthur Bedrosian v. United States, a recent FBAR willfulness penalty […]
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Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess?

Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess? In general, the filing of an amended return does nothing […]
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