Orange County Tax Attorney Blog

United Way’s Volunteer Income Tax Assistance Program in Orange County Needs Volunteers

The Orange County Register put out an article last (click here) week highlighting the United Way of Orange County’s need for volunteers for the upcoming tax […]

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]

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 […]

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 […]