Orange County Tax Attorney Blog

IRS Changes Procedures to Deny In-Person and Face-to-Face Conferences

In yet another blow to taxpayers, the IRS has amended its Internal Revenue Manual, which provides procedures for its employees to follow, to deny the right […]

Ecigarette Sellers To Be Subject to Registration Requirements for Cigarette and Tobacco Products Retailer Licenses Starting January 1 2017

The California State Board of Equalization issued a press release on November 2, 2016, advising “E-Cig” sellers of the new license registration requirements starting on January […]

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 […]

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 […]
Jersey Shore

What’s the Situation With “The Situation” of Jersey Shore?

  A blast from the past just came across the headlines recently surrounding a member of the hit show of 2009, Jersey Shore. I had previously […]

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 […]

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, […]
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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 […]
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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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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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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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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 […]