Orange County Tax Attorney Blog

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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 […]

Washington D.C. Tax Preparer Found Guilty of Filing False Income Tax Returns for Herself and for Her Clients

As the tax season comes upon us, the IRS is urging taxpayers to be careful when choosing a tax preparer. We are reminded of this by […]

Bookkeeper Committing Tax Fraud Gets Prison Sentence

Earlier this month, a bookkeeper of a charter bus company was sentenced to prison for engaging in tax fraud by failing to report close to $1 […]

Permanent Injunction Imposed on Las Vegas Couple Involved in Illegal Tax Scheme

Return preparer fraud continues to be a major concern of the IRS.  A recent case out of Las Vegas details how a husband and wife team […]

Attorney Found Guilty of Tax Fraud

Yesterday, the U.S. Department of Justice’s Tax Division won a conviction against a New York attorney for failing to report income on his 2007, 2008 and […]

Before the Tax Season Starts, A Reminder to Choose Your Return Preparer Carefully

Earlier this month, the DOJ issued a press release that buried the lead, titled, “Former eBAY Manager Pleads Guilty To Stealing More Than $200,000 In IRS […]

Republican Congressman Michael Grimm to Resign Following Guilty Plea to Tax Charge

On December 30, 2014, New York Representative Michael Grimm (Rep.) announced he would resign as of January 5, 2015, according to a report by the Associated Press and […]

Attitude Survey Shows Lower Satisfaction With IRS Customer Service

On December 8, 2014, the IRS Oversight Board released its 2014 Taxpayer Attitude Survey. As is probably no surprise to many tax professionals who deal with […]

Los Angeles Area Car Dealers Sentenced for Tax Evasion

Last week the Pasadena Star News reported that two car-dealing brothers were sentenced by the LA Superior Court to three year sentences.  They pleaded no contest to […]

Star of “Jersey Shore” Indicted for Tax Fraud

Michael “The Situation” Sorrentino and his brother/manager Marc Sorrentingo were indicted last week for allegedly failing to pay taxes on $8.9 million of income, according to […]

Newport Beach Executive Sentenced to 7 Years For $180 million Unreported Income

The Orange County DA’s office issued a press release yesterday reporting that Richard Engel, a 70 year old Newport Beach man, was sentenced to seven years […]