Orange County Tax Attorney Blog

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What Actions Extend the Length of the IRS’s Time to Collect?

What Actions Extend the Length of the IRS’s Time to Collect? Under the general rule, the IRS must collect taxes within 10 years of the date […]
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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 […]

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 […]

Is a Tax LLM a Good Idea? Part 3.1: Ranking the Top Tax LLM Programs.

Currently, there are a few places that you may find rankings of the master of laws in taxation programs. One of the obvious places to look […]
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Is a Tax LLM Worth It? Part 2.1 of “Is a Tax LLM a Good Idea?”

What Is the Value of a Tax LLM? Whether a Master of Laws in Taxation is worth the cost, of course, is going to vary based […]

Is Getting a Tax LLM A Good Idea? Part 1: LLM Programs Grew More Competitive…

A question law students and recent law school graduates ask with great frequency is whether they should pursue a Tax LLM. To a great extent, the […]
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