Orange County Tax Attorney Blog

Tampon Tax Relief Vetoed by California Governor Brown

Affirming, perhaps, that the one thing California loves more than being progressive is being expensive, Governor Jerry Brown vetoed a bill that would have exempted tampons […]

North Carolina Man Indicted for Allegedly Filing False Lien

The Department of Justice issued a press release regarding the indictment of a North Carolina man alleging the filing of false tax returns and interfering with […]

US Tax Court Sides With Whistleblower in Award Case

In June, the Tax Court issued its opinion in 21276-13W v. Commissioner, 144 T.C. No. 15 (2016).  This is one of the better written case opinions […]

After Attempt to Sneak Bank Statements From Israel, Los Angeles Man Pleads Guilty

Tip of the hat to the article in Bloomberg which recently highlighted a local Los Angeles business man’s captivating cat-and-mouse method of receiving bank statements.  According […]

Santa Barbara Man Pleads Guilty to Tax Charges

As I’ve discussed in previous posts, the IRS isn’t the only one prosecuting tax charges.   On July 20, 2016, the District Attorney’s Office for the […]

OC’s Assessed Property Tax Roll Reaches over $500 Billion

That’s billion, with a “B.”  The OC Register is reporting (link here) that a 5.5 percent increase in assessments of real property tax citing a number […]

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 […]
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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 […]
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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 […]
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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 […]
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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 […]
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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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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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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 […]