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. […]

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 […]
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How Long Do You Have to File a Complaint in District Court Once a Refund Claim is Rejected by the IRS?

  Under 26 U.S.C. § 6532(a)(1), a taxpayer generally may not wait longer than 2 years from the issuance of the IRS’s disallowance of the administrative […]
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Application of the Local Action Doctrine in Federal Tax Lien Cases

A “Local Action” is an action that must be brought in the state where the property is located.  A taxpayer or third party seeking to clear […]
What is an IRS jeopardy levy

What Is An IRS Jeopardy Levy?

When the IRS “makes a finding that the collection of such tax is in Jeopardy,” the IRS can make notice and demand for immediate payment and, […]
When can IRS levy bank account

When Can the IRS Levy or Garnish?

When can the IRS levy or garnish your wages or bank accounts? In general, the IRS can issue a levy after the tax is assessed (meaning […]
Full payment rule tax penalties interest

Does the Full Payment Rule in District Court Tax Refund Suits Include Tax, Penalties, and Interest?

Does the Full Payment Rule in Federal District Court Tax Refund Suits Include Tax, Penalties, and Interest? It has long been the law that, before a […]

Using Interpreters in Summary Judgment Motions In Federal District Court

Using Interpreters in Summary Judgment Motions in Federal District Court Interpreters are generally used in two contexts in relation to summary judgment motions in federal district […]
Will the IRS waive penalties

Will the IRS Waive Penalties?

Will the IRS Waive Penalties? In general, with the exception of the fraud penalty, most IRS penalties will not apply where the taxpayer had reasonable cause […]

The Limits of Waivers of Attorney Conflicts of Interest In Federal Criminal Cases

The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of […]
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