Orange County Tax Attorney Blog

Can an Unrecorded Deed Defeat an IRS Federal Tax Lien?

Can an Unrecorded Deed Defeat an IRS Federal Tax Lien in California? Yes, an unrecorded deed for California real property can defeat a later-arising IRS federal […]

Author K. Slaughter Found Liable for Employment Taxes, But Not Penalties, in Tax Court Opinion

Author K. Slaughter Found Liable for Employment Taxes, But Not Penalties in U.S. Tax Court Opinion. In K. Slaughter v. Commissioner, T.C. Memo. 2019-65, an opinion […]

Attorney’s Fees in Interpleader Action? Not If It Impairs Recovery of Federal Tax Lien.

Attorney’s Fees in Interpleader Action? Not If It Impairs Recovery of Federal Tax Lien. Can the party filing an interpleader in California recover the costs and […]

Issuing a State Court Subpoena to Federal Officials: Beware the Touhy Doctrine.

Issuing a State Court Subpoena to Federal Officials: Beware the Touhy Doctrine. Can you subpoena an IRS or another Federal official in a state court action? […]

Enforcement of Money Judgments Against Property in Jurisdiction of California Probate Court: The Interaction Between Cal. Code. Civ. Proc. Sections 709.030, 695.010 and 697.310

Enforcement of Money Judgments Against Property in Jurisdiction of California Probate Court: The Interaction Between Cal. Code. Civ. Proc. Sections 709.030, 695.010 and 697.310 One issue […]

Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government

In tax cases, the IRS and Department of Justice will generally prosecute cases under Title 26, the Internal Revenue Code. However, if a false statement is […]

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 […]

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. […]

IRS Improperly Withholding Documents In Response to Freedom of Information Act Requests

On September 18, 2015, the Treasury Inspector General for Tax Administration (TIGTA), a bureau of the department of the Treasury, issued its Fiscal Year 2015 Statutory Review […]

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 […]

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 […]
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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 […]