Will the IRS Waive Penalties? In general, with the exception of the fraud penalty, most IRS penalties will not apply where the taxpayer had reasonable cause […]
The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of […]
Does the IRS Have Discretion to Apply Lower FBAR Penalties? The Ninth Circuit recently found, in United States v. Boyd, that the IRS may only apply […]
When Are Legal Fees Deductible as Employee Business Expenses? In Guill v. Commissioner, 112 T.C. 325 (1999), the United States Tax Court succinctly explained the deductibility […]
When Is a California Tax Attorney’s Conflict of Interest Unwaivable? A court may find that a conflict of interest by a California attorney may not be […]
Does an Amended Tax Return Extend the IRS Statute of Limitations? In general, no. The ordinary IRS statute of limitations for the IRS to complete its […]
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 […]
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 […]
The IRS Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work
The IRS Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work If you have ever been to the “Ziggurat,” the IRS […]
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 […]