Orange County Tax Attorney Blog

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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 […]
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Does the IRS Have Discretion to Apply Lower FBAR Penalties?

Does the IRS Have Discretion to Apply Lower FBAR Penalties? On May 13, 2015, the IRS issued a memorandum to all IRS LB&I, SB/SE, and TE/GE […]

The Limits of Waivers of Attorney Conflicts of Interest In Federal Criminal Cases

The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of […]
Will the IRS waive penalties

Will the IRS Waive Penalties?

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 […]

Using Interpreters in Summary Judgment Motions In Federal District Court

Using Interpreters in Summary Judgment Motions in Federal District Court Interpreters are generally used in two contexts in relation to summary judgment motions in federal district […]
Full payment rule tax penalties interest

Does the Full Payment Rule in District Court Tax Refund Suits Include Tax, Penalties, and Interest?

Does the Full Payment Rule in Federal District Court Tax Refund Suits Include Tax, Penalties, and Interest? It has long been the law that, before a […]
When can IRS levy bank account

When Can the IRS Levy or Garnish?

When can the IRS levy or garnish your wages or bank accounts? In general, the IRS can issue a levy after the tax is assessed (meaning […]
What is an IRS jeopardy levy

What Is An IRS Jeopardy Levy?

When the IRS “makes a finding that the collection of such tax is in Jeopardy,” the IRS can make notice and demand for immediate payment and, […]
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Application of the Local Action Doctrine in Federal Tax Lien Cases

A “Local Action” is an action that must be brought in the state where the property is located.  A taxpayer or third party seeking to clear […]
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How Long Do You Have to File a Complaint in District Court Once a Refund Claim is Rejected by the IRS?

  Under 26 U.S.C. § 6532(a)(1), a taxpayer generally may not wait longer than 2 years from the issuance of the IRS’s disallowance of the administrative […]