Orange County Tax Attorney Blog

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 […]
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 […]

Release or Discharge of Property from a Third Party’s Federal Tax Lien

  When a Federal tax lien for one person is erroneously filed against another person’s property, that tax lien may cause an escrow company to pay […]
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Snipes v. Commissioner, T.C. Memo. 2018-184

  T.C. Memo. 2018-184 UNITED STATES TAX COURT W.T. SNIPES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27902-15L. Filed November 1, 2018. P has […]
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Salt Lake City District Court Bars Pair from Promoting Solar Tax Credit Scheme

A recent release by the United States Department of Justice covered a $50 million-dollar judgement against two individuals and two companies. The full release can be […]
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What Does it Mean for a Lien to be “Choate?”

  The term “choate” typically arises when there is a dispute as to when one lien is competing with another for the right to be paid […]
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Norman v. United States – Court of Federal Claims Holds FBAR Willfulness Penalty Not Limited Contrary to Colliot District Court

  Blogger’s Note:   It appears to me the trial-level judge in the Court of Federal Claims has determined the regulation at issue is invalid because it […]

Wadhan v. United States – Another District Court Opinion Following Colliot and Limiting FBAR Penalty

1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Marcia S. Krieger Civil Action No. 17-CV-1287-MSK UNITED STATES OF AMERICA, Plaintiffs, […]

United States v. Colliot, Defendant., U.S. District Court, W.D. Texas, 2018-1 U.S.T.C. ¶50,259, (May 16, 2018) – District Court Holds FBAR Penalty Limited

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION UNITED STATES OF AMERICA, -vs- DOMINIQUE G. COLLIOT, Defendant. CAUSE NO.: AU-16-CA-01281-SS […]
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