Orange County Tax Attorney Blog

United Way’s Volunteer Income Tax Assistance Program in Orange County Needs Volunteers

The Orange County Register put out an article last (click here) week highlighting the United Way of Orange County’s need for volunteers for the upcoming tax […]

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]

IRS Changes Procedures to Deny In-Person and Face-to-Face Conferences

In yet another blow to taxpayers, the IRS has amended its Internal Revenue Manual, which provides procedures for its employees to follow, to deny the right […]

Ecigarette Sellers To Be Subject to Registration Requirements for Cigarette and Tobacco Products Retailer Licenses Starting January 1 2017

The California State Board of Equalization issued a press release on November 2, 2016, advising “E-Cig” sellers of the new license registration requirements starting on January […]

Retired Professor Pleads to Conspiracy to Submit False Expatriation Statement and Tax and FBAR Conduct

Affirming that the DOJ is still prosecuting at least the more egregious offshore-reporting cases, the DOJ issued a press release recently detailing the plea agreement of an […]

IRS Criminal Special Agent Indicted For Filing False Returns and Obstruction

In a case of dabbling in too much of one’s own product, or the dog chasing its own tail, so to speak, an IRS Special Agent […]

When Are Legal Fees Deductible as Employee Business Expenses?

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 […]
tax attorney newport beach, tax attorney orange county, newport beach estate planning attorney

When Is a California Tax Attorney’s Conflict of Interest Unwaivable?

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 […]
tax attorney orange county, tax attorney newport beach, estate planning newport beach, estate planning attorney orange county

Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess?

Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess? In general, the filing of an amended return does nothing […]
tax attorney newport beach, tax attorney orange county

Bedrosian v. United States – FBAR Wilfullness Penalty Standard Considered by Third Circuit Court of Appeals

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 […]

Kimble v. United States, Court of Claims No. 17-421 – FBAR Willfulness Penalty Case

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’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 […]
tax attorney newport beach, tax attorney orange county

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 […]
tax attorney newport beach, tax attorney orange county.

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 […]
tax attorney newport beach, tax attorney orange county

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 […]
tax attorney orange county, tax attorney newport beach

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 […]