Orange County Tax Attorney Blog

Fullerton Man Pleads Guilty to False Return Preparation

A local return preparer has pleaded guilty to preparing returns claiming over a million dollars in false refunds.  In the height of tax season, this operates […]

San Diego Legalizes Recreational Marijuana Dispensaries and Looks Forward to Taxing Them

The San Diego Union Tribune recently published an article highlighting the City of San Diego’s   recent approval of recreational marijuana dispensaries.  As has been implicit […]

Stolen Identity Refund Fraud Committed by Inmate

In my experience as a federal tax prosecutor, I have previously seen cases where someone in prison (in one case on charges of return fraud already) […]

The Value of a Tax LLM After Your First Job: Part 2.2 of “Is Getting a Tax LLM a Good Idea?”

In an earlier post, I discussed whether a tax LLM was worth the cost largely as a function of its affect on landing one’s first tax […]

FINCEN to Allow Automatic Extensions of FBAR Deadline

As noted in a prior post (here), H.R. 3236 became Public Law No. 114-41 and provided several directives to the Secretary of the Treasury to issue regulations providing […]

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 […]

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 […]