Orange County Tax Attorney Blog

Bakersfield Car Dealer Bros Plead Guilty to Failing to File Form 8300 Cash Transaction Reports

Reminding taxpayers that there are more than one way the government can skin a cat, the DOJ issued a press release last week publicizing the guilty […]

Northern California Woman Pleads Guilty to False Return Omitting Bonus Pay

The Tax Division of the U.S. Department of Justice issued a press release yesterday advising of the guilty plea of a medical office director in Northern […]

Buffet Owner Pleads Guilty to Tax Evasion

I have previously blogged about non-income tax evasion cases prosecuted locally.  A little further away, there is another example, here where a buffet owner pleaded guilty […]

Fullerton Man Pleads Guilty to False Return Preparation

A local return preparer has pleaded guilty to preparing returns claiming over a million dollars in false refunds.  In the height of tax season, this operates […]

San Diego Legalizes Recreational Marijuana Dispensaries and Looks Forward to Taxing Them

The San Diego Union Tribune recently published an article highlighting the City of San Diego’s   recent approval of recreational marijuana dispensaries.  As has been implicit […]

Stolen Identity Refund Fraud Committed by Inmate

In my experience as a federal tax prosecutor, I have previously seen cases where someone in prison (in one case on charges of return fraud already) […]

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 […]
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