Orange County Tax Attorney Blog

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Application of the Local Action Doctrine in Federal Tax Lien Cases

A “Local Action” is an action that must be brought in the state where the property is located.  A taxpayer or third party seeking to clear […]
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How Long Do You Have to File a Complaint in District Court Once a Refund Claim is Rejected by the IRS?

  Under 26 U.S.C. § 6532(a)(1), a taxpayer generally may not wait longer than 2 years from the issuance of the IRS’s disallowance of the administrative […]
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Release or Discharge of Property from a Third Party’s Federal Tax Lien

  When a Federal tax lien for one person is erroneously filed against another person’s property, that tax lien may cause an escrow company to pay […]
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Snipes v. Commissioner, T.C. Memo. 2018-184

  T.C. Memo. 2018-184 UNITED STATES TAX COURT W.T. SNIPES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27902-15L. Filed November 1, 2018. P has […]
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Salt Lake City District Court Bars Pair from Promoting Solar Tax Credit Scheme

  A recent release by the United States Department of Justice covered a $50 million-dollar judgement against two individuals and two companies. The full release can […]
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What Does it Mean for a Lien to be “Choate?”

  The term “choate” typically arises when there is a dispute as to when one lien is competing with another for the right to be paid […]

Celebrities Getting Into the Medical Marijuana Business

The OC Register recently published an interesting article on the growing medical marijuana business, focusing on the fact that several celebrities, including most recently Roseanne Barr, […]

Revised FBAR Rules for Finance Pros Proposed by FinCEN

FinCEN is the Financial Crimes Enforcement Network, a bureau of the Treasury Department, which is tasked, among other things, with monitoring offshore financial transactions in order […]

Hollywood Tax – Ex-SAG Benefit Plan Official Guilty Plea and More

The National Legal and Policy Center published an article yesterday (nlpc.org/2016/03/28/ex-sag-benefit-plan-official-pleads-guilty-700k-tax-evasion/) on the guilty plea of Nader Karimi.  According to that article he pleaded guilty to […]

Tax Court Judge Kroupa Indicted

In news that is rocking the tax community, the Department of Justice has issued a press release announcing that Judge Diane Kroupa and her husband have […]

Hacienda Heights Man Sentenced in Tax Return ID Theft Case

The San Gabriel Valley Tribune reported earlier this month on yet another tax return-related identity theft sentencing in California.  This time with was a 63 year […]

$14 Million In Refunds Issued by IRS in Stolen Identity Refund Fraud Scheme Indicted

Yet another tax return related identity theft scheme was recently indicted, this one with ties all across Orange County from La Habra to Newport Beach.  I […]

How Long Will OVDP/OVDI Be Available?

WARNING: Update 3/13/2018.  The IRS has announced the formal Offshore Voluntary Program discussed below will be closed on September 28, 2018.  For more, see our post […]

Canadian Orange County Resident on Lamb for 5 Years Extradited From Germany

The IRS issued a press release earlier this month about the sentencing of Donald Baxi, a former Orange County resident with Canadian citizenship.  Interestingly, he had […]

Pro Football Hall of Famer and San Diego Attorney Pleads Guilty to Tax Charge

The US Department of Justice issued a press release recently announcing the guilty plea of Hall of Fame football player Ron Mix, who is 78 years […]

An Instructive Case: Non-Filer Charged and Tried for Tax Evasion

Many taxpayers may be surprised that failure to file a Federal tax return by the April deadline is technically criminal, if it is intentionally not filed […]