Orange County Tax Attorney Blog

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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 […]
tax attorney newport beach

Norman v. United States – Court of Federal Claims Holds FBAR Willfulness Penalty Not Limited Contrary to Colliot District Court

  Blogger’s Note:   It appears to me the trial-level judge in the Court of Federal Claims has determined the regulation at issue is invalid because it […]

Wadhan v. United States – Another District Court Opinion Following Colliot and Limiting FBAR Penalty

1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Marcia S. Krieger Civil Action No. 17-CV-1287-MSK UNITED STATES OF AMERICA, Plaintiffs, […]

United States v. Colliot, Defendant., U.S. District Court, W.D. Texas, 2018-1 U.S.T.C. ¶50,259, (May 16, 2018) – District Court Holds FBAR Penalty Limited

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION UNITED STATES OF AMERICA, -vs- DOMINIQUE G. COLLIOT, Defendant. CAUSE NO.: AU-16-CA-01281-SS […]
Jersey Shore

What’s the Situation With “The Situation” of Jersey Shore?

A blast from the past just came across the headlines recently surrounding a member of the hit show of 2009, Jersey Shore. I had previously covered […]

IRS Changes Procedures to Deny In-Person and Face-to-Face Conferences

In yet another blow to taxpayers, the IRS has amended its Internal Revenue Manual, which provides procedures for its employees to follow, to deny the right […]

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]

United Way’s Volunteer Income Tax Assistance Program in Orange County Needs Volunteers

The Orange County Register put out an article last (click here) week highlighting the United Way of Orange County’s need for volunteers for the upcoming tax […]

FINCEN to Allow Automatic Extensions of FBAR Deadline

As noted in a prior post (here), H.R. 3236 became Public Law No. 114-41 and provided several directives to the Secretary of the Treasury to issue regulations providing […]

The Value of a Tax LLM After Your First Job: Part 2.2 of “Is Getting a Tax LLM a Good Idea?”

In an earlier post, I discussed whether a tax LLM was worth the cost largely as a function of its affect on landing one’s first tax […]

Stolen Identity Refund Fraud Committed by Inmate

In my experience as a federal tax prosecutor, I have previously seen cases where someone in prison (in one case on charges of return fraud already) […]

San Diego Legalizes Recreational Marijuana Dispensaries and Looks Forward to Taxing Them

The San Diego Union Tribune recently published an article highlighting the City of San Diego’s   recent approval of recreational marijuana dispensaries.  As has been implicit […]

Fullerton Man Pleads Guilty to False Return Preparation

A local return preparer has pleaded guilty to preparing returns claiming over a million dollars in false refunds.  In the height of tax season, this operates […]

Buffet Owner Pleads Guilty to Tax Evasion

I have previously blogged about non-income tax evasion cases prosecuted locally.  A little further away, there is another example, here where a buffet owner pleaded guilty […]

Northern California Woman Pleads Guilty to False Return Omitting Bonus Pay

The Tax Division of the U.S. Department of Justice issued a press release yesterday advising of the guilty plea of a medical office director in Northern […]