Orange County Tax Attorney Blog

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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 […]
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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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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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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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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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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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In Honor of Tax Identity Theft Awareness Week… a Roundup of Local Cases

There are always plenty of Stolen Identity Refund Fraud prosecutions going on, but here are some recent ones of local interest: A Utah woman pleaded guilty to […]
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Permanent Injunction Imposed on Las Vegas Couple Involved in Illegal Tax Scheme

Return preparer fraud continues to be a major concern of the IRS.  A recent case out of Las Vegas details how a husband and wife team […]
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Bookkeeper Committing Tax Fraud Gets Prison Sentence

Earlier this month, a bookkeeper of a charter bus company was sentenced to prison for engaging in tax fraud by failing to report close to $1 […]
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Washington D.C. Tax Preparer Found Guilty of Filing False Income Tax Returns for Herself and for Her Clients

As the tax season comes upon us, the IRS is urging taxpayers to be careful when choosing a tax preparer. We are reminded of this by […]
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Laguna Beach Doctor Pleads Guilty to Failing to Report Foreign Account

The U.S. Department of Justice and the United States Attorney’s Office for the Central District of California announced today another guilty plea in an FBAR case, this […]
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Lancaster Man Pleads Guilty to Tax Charges Related to EDD Scheme

The IRS issued a press release announcing that Carl Artis, a Lancaster man, pleaded guilty before Judge Wu (a fellow UChicago Law graduate) to tax charges. […]
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57 Month Sentence for San Francisco Man Who Pleaded Guilty to Embezzlement from Non-Profit

I’ve written before about embezzlement or misappropriation leading to tax charges.  The recent sentencing of Robert Bradley Strahan is another example of that, though in a […]
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Opinion of the Day: Seventh Circuit Judge Richard Posner Sits as District Court Judge in Criminal Tax Case

While I was a law student at the University of Chicago, I was fortunate enough to have Richard Posner, one of the more well known federal […]
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IRS Issues Guidance for Choosing a Tax Return Preparer

The IRS’s Office of Professional Responsibility has long been trying to be a force in regulating and imposing some form of quality control over return preparers. […]
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Ex-Casino Owner and Ex-NFL Punter Sentenced in Criminal Tax Case

Hot on the heels of the IRS’s push for taxpayers to be more choosy about their return preparers, the DOJ issued a press release last week […]
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