Orange County Tax Attorney Blog

Kimble v. United States, Court of Claims No. 17-421 – FBAR Willfulness Penalty Case

The below is the HTML text of the original opinion in the Kimble v. United States opinion in the United States Court of Claims, a wilful […]
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Bedrosian v. United States – FBAR Wilfullness Penalty Standard Considered by Third Circuit Court of Appeals

Recent Tax Opinion Highlight: The opinion of United States Court of Appeals for the 3rd Circuit in Arthur Bedrosian v. United States, a recent FBAR willfulness penalty […]
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Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess?

Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess? In general, the filing of an amended return does nothing […]
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When Is a California Tax Attorney’s Conflict of Interest Unwaivable?

When Is a California Tax Attorney’s Conflict of Interest Unwaivable? A court may find that a conflict of interest by a California attorney may not be […]

When Are Legal Fees Deductible as Employee Business Expenses?

When Are Legal Fees Deductible as Employee Business Expenses? In Guill v. Commissioner, 112 T.C. 325 (1999), the United States Tax Court succinctly explained the deductibility […]
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What Actions Extend the Length of the IRS’s Time to Collect?

What Actions Extend the Length of the IRS’s Time to Collect? Under the general rule, the IRS must collect taxes within 10 years of the date […]

Northern California Thai Restaurant Owner Sentenced for Underpaying Undocumented Workers and Tax Fraud

Paying undocumented workers under the table or having off-the-books cash employees often goes hand in hand with tax charges.  The connection arises like a domino effect. […]

Motorcycle Racing Business Owner Pleads to Tax Fraud

Per a recent DOJ press release (which can be seen by clicking here) Dan Kyle, owner of Kyle Racing in Sand City, CA, pleaded guilty to […]
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Rap Star DMX Arrested Under Tax Fraud Charges – Tax Evasion and Failure to File Returns

Tip of the hat to the Billboard.com’s article for bringing this music industry tax news to my attention.  A recent DOJ press release is reporting that […]