Orange County Tax Attorney Blog

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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 be […]
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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 […]
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Norman v. United States – Court of Federal Claims Holds FBAR Willfulness Penalty Not Limited Contrary to Colliot District Court

  Blogger’s Note:   It appears to me the trial-level judge in the Court of Federal Claims has determined the regulation at issue is invalid because it […]

Wadhan v. United States – Another District Court Opinion Following Colliot and Limiting FBAR Penalty

1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Marcia S. Krieger Civil Action No. 17-CV-1287-MSK UNITED STATES OF AMERICA, Plaintiffs, […]

United States v. Colliot, Defendant., U.S. District Court, W.D. Texas, 2018-1 U.S.T.C. ¶50,259, (May 16, 2018) – District Court Holds FBAR Penalty Limited

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION UNITED STATES OF AMERICA, -vs- DOMINIQUE G. COLLIOT, Defendant. CAUSE NO.: AU-16-CA-01281-SS […]

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 […]

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 Thai Restaurant Owner Sentenced for Underpaying Undocumented Workers and Tax Fraud

Paying undocumented workers under the table or having off-the-books cash employees often goes hand in hand with tax charges.  The connection arises like a domino effect. […]

Austin v. Commissioner, T.C. Memo. 2017-69

The Untied States Tax Court issued its opinion in Austin v. Commissioner, T.C. Memo. 2017-69, on April 24, 2017.  The full text of the opinion is […]

Motorcycle Racing Business Owner Pleads to Tax Fraud

Per a recent DOJ press release (which can be seen by clicking here) Dan Kyle, owner of Kyle Racing in Sand City, CA, pleaded guilty to […]

Why is Golden Gate University’s MST (Master’s of Science in Taxation) Program So Well Known?

Golden Gate University has its main campus in San Francisco. But, Golden Gate University also has the most popular, based on my anecdotal observations, Master’s of […]

Ranking the Top Tax LLM Programs: Part 3.2 of Is a Tax LLM a Good Idea? [2019 Update]

Tax LLM Rankings. I last posted about the top Master of Laws in Taxation programs about four years ago.  Really, not much can change in that […]

Introducing the California Department of Tax and Fee Administration and the Office of Tax Appeals

On June 15th, Senate Bill (SB) 86 was passed.  The bill was called the “Taxpayer Transparency and Fairness Act,” and the full text can be found […]
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Rap Star DMX Arrested Under Tax Fraud Charges – Tax Evasion and Failure to File Returns

Tip of the hat to the Billboard.com’s article for bringing this music industry tax news to my attention.  A recent DOJ press release is reporting that […]

U.S. Senate Committee Declines to Change DOJ Medical Marijuana Policy

In August of 2013, the Justice Department announced a marijuana enforcement policy which still endures, at least for the time being.  That “medical marijuana” policy is […]
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