Orange County Tax Attorney Blog

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 […]

Former IRS Revenue Officer Pleads Guilty to Tax Evasion

The Department of Justice issued a press release setting out a cautionary tale of what not to do, outlining a litany of affirmative act comprising the […]

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 […]
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Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens

Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens California’s Homestead exemption is found in Chapter 4 of Division […]

When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien?

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 […]
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Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF

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 […]

Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute

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 […]

Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government

In tax cases, the IRS and Department of Justice will generally prosecute cases under Title 26, the Internal Revenue Code. However, if a false statement is […]

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

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.

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.

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 Tax Court Opinion

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?

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 […]