Orange County Tax Attorney Blog

Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute

What is the Federal Insolvency Statute? Where the delinquent taxpayer is insolvent but has not filed a petition in bankruptcy, the IRS’ prior right to payment […]
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Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF

On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 […]

When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien?

When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien? Judicial discretion to decline foreclosure in Federal […]
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Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens

Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens California’s Homestead exemption is found in Chapter 4 of Division […]
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Does Res Judicata Apply to Stipulated Tax Court Decisions?

Does Res Judicata Apply to Stipulated U.S. Tax Court Decisions? The judicial principle of res judicata applies to stipulated Tax Court Decisions. However, if the stipulated […]
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What Is a Federal IRS Tax Lien?

What is a federal IRS tax lien? A federal IRS tax lien is a lien for unpaid tax liabilities which arises in favor of the United […]

Toner Cartridge Thief Pleads Guilty to Tax Fraud

Earlier this month, Eduardo C. Partida, a resident of South Gate, pleaded guilty to one count of tax fraud, according to an IRS press release.  The […]

Los Angeles Area Car Dealers Sentenced for Tax Evasion

Last week the Pasadena Star News reported that two car-dealing brothers were sentenced by the LA Superior Court to three year sentences.  They pleaded no contest to […]

Attitude Survey Shows Lower Satisfaction With IRS Customer Service

On December 8, 2014, the IRS Oversight Board released its 2014 Taxpayer Attitude Survey. As is probably no surprise to many tax professionals who deal with […]

Republican Congressman Michael Grimm to Resign Following Guilty Plea to Tax Charge

On December 30, 2014, New York Representative Michael Grimm (Rep.) announced he would resign as of January 5, 2015, according to a report by the Associated Press and […]

Before the Tax Season Starts, A Reminder to Choose Your Return Preparer Carefully

Earlier this month, the DOJ issued a press release that buried the lead, titled, “Former eBAY Manager Pleads Guilty To Stealing More Than $200,000 In IRS […]

Board of Equalization Will Look for Sales Suppression in 2015

California’s Board of Equalization issued a Special Notice (available at www.boe.ca.gov/news/2014/l386.pdf) in the latter part of 2014 making it clear that they were interested in prosecuting sales suppression […]

Letter 5105 Being Sent to Select Return Preparers in January – How Can You Respond?

As a tax controversy attorney, although I don’t prepare returns myself, I try and stay in touch with issues affecting return preparers, CPAs, and enrolled agents. […]

Paying for College is Hard, But Doing Time is Harder: College Kids Arrested for Tax Refund ID Fraud

In November, the United States Attorney’s Office for the Southern District of Florida  issued an interesting press release detailing the arrest of 17 people, including 14 students […]

Attorney Found Guilty of Tax Fraud

Yesterday, the U.S. Department of Justice’s Tax Division won a conviction against a New York attorney for failing to report income on his 2007, 2008 and […]

Tax Identity Theft Awareness Week Is This Week! Hooray?

Tax Identity Theft Awareness week, so designated by the FTC, ends on January 30, 2015. As anyone acquainted with me knows, I was the Stolen Identity […]