Orange County Tax Attorney Blog

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 […]

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 […]

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 […]

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 […]

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 […]

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. […]

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 […]
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 covered […]

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 be […]
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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 […]

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 […]