When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien? Judicial discretion to decline foreclosure in Federal […]
On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 […]
What is the Federal Insolvency Statute? Where the delinquent taxpayer is insolvent but has not filed a petition in bankruptcy, the IRS’ prior right to payment […]
What is the 18 USC § 1001 statute of limitations? The statute of limitations for bringing charges under 18 U.S.C. Section 1001 is set by 18 […]
Enforcement of Money Judgments Against Property in Jurisdiction of California Probate Court: The Interaction Between Cal. Code. Civ. Proc. Sections 709.030, 695.010 and 697.310 One issue […]
Issuing a State Court Subpoena to Federal Officials: Beware the Touhy Doctrine. Can you subpoena an IRS or another Federal official in a state court action? […]
Attorney’s Fees in Interpleader Action? Not If It Impairs Recovery of Federal Tax Lien. Can the party filing an interpleader in California recover the costs and […]
Author K. Slaughter Found Liable for Employment Taxes, But Not Penalties in U.S. Tax Court Opinion. In K. Slaughter v. Commissioner, T.C. Memo. 2019-65, an opinion […]
Can an Unrecorded Deed Defeat an IRS Federal Tax Lien in California? Yes, an unrecorded deed for California real property can defeat a later-arising IRS federal […]
The Supreme Court Issued Its Opinion in North Carolina Department of Revenue v. Kimberly Rice Kaestner 1992 Family Trust on June 21, 2019. Click here for […]