Orange County Tax Attorney Blog

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, […]
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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 […]

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 be […]

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 […]

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 […]

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 […]

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 […]

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 […]

Tampon Tax Relief Vetoed by California Governor Brown

Affirming, perhaps, that the one thing California loves more than being progressive is being expensive, Governor Jerry Brown vetoed a bill that would have exempted tampons […]

Former IRS Revenue Officer Pleads Guilty to Tax Evasion

The Department of Justice issued a press release setting out a cautionary tale of what not to do, outlining a litany of affirmative act comprising the […]

IRS Criminal Special Agent Indicted For Filing False Returns and Obstruction

In a case of dabbling in too much of one’s own product, or the dog chasing its own tail, so to speak, an IRS Special Agent […]

Retired Professor Pleads to Conspiracy to Submit False Expatriation Statement and Tax and FBAR Conduct

Affirming that the DOJ is still prosecuting at least the more egregious offshore-reporting cases, the DOJ issued a press release recently detailing the plea agreement of an […]

Ecigarette Sellers To Be Subject to Registration Requirements for Cigarette and Tobacco Products Retailer Licenses Starting January 1 2017

The California State Board of Equalization issued a press release on November 2, 2016, advising “E-Cig” sellers of the new license registration requirements starting on January […]