Orange County Tax Attorney Blog

North Carolina Man Indicted for Allegedly Filing False Lien

The Department of Justice issued a press release regarding the indictment of a North Carolina man alleging the filing of false tax returns and interfering with […]

US Tax Court Sides With Whistleblower in Award Case

In June, the Tax Court issued its opinion in 21276-13W v. Commissioner, 144 T.C. No. 15 (2016).  This is one of the better written case opinions […]

After Attempt to Sneak Bank Statements From Israel, Los Angeles Man Pleads Guilty

Tip of the hat to the article in Bloomberg which recently highlighted a local Los Angeles business man’s captivating cat-and-mouse method of receiving bank statements.  According […]

Santa Barbara Man Pleads Guilty to Tax Charges

As I’ve discussed in previous posts, the IRS isn’t the only one prosecuting tax charges.   On July 20, 2016, the District Attorney’s Office for the […]

OC’s Assessed Property Tax Roll Reaches over $500 Billion

That’s billion, with a “B.”  The OC Register is reporting (link here) that a 5.5 percent increase in assessments of real property tax citing a number […]

An Instructive Case: Non-Filer Charged and Tried for Tax Evasion

Many taxpayers may be surprised that failure to file a Federal tax return by the April deadline is technically criminal, if it is intentionally not filed […]
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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 […]
Interpreters summary judgment motions

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 […]

When Can I take Casualty Theft Losses On My Tax Return?

When Can I take Casualty Theft Losses On My Tax Return? Per 26 U.S.C. § 165(c) casualty loss deductions can be taken for theft.  Per IRS […]