Orange County Tax Attorney Blog

Murrieta Tax Preparer Gets No Jail Sentence for Tax Crime

A Murrieta return preparer is reported by patch.com (here) to have received a sentence of home detention, probation, and community service, although the sentencing guidelines provided […]

The General Rules Applicable to Federal Interpleader Actions Involving Federal Tax Liens

Interpleader actions are authorized by 28 U.S.C. § 1335 and Rule 22 of the Federal Rules of Civil Procedure where plaintiffs holding funds to property upon […]

Former Head of Foster Agency Sentenced for Theft, Money Laundering, Tax Evasion

The DOJ issued a press release in June highlighting the sentencing, after conviction at jury trial, of an Oregon woman found guilty of stealing over $1 […]

How Long Do You Have to File a Franchise Tax Board Tax Refund Suit?

Question: How Long Do You Have to File a California Franchise Tax Board Income Tax Refund Suit? Answer: Generally, if you have full paid the tax […]

Recent Conviction Illustrates Connection Between Use of Nominees and Tax Evasion

A Recent Conviction in Hawaii’s U.S. District Court Illustrates How the Use of Nominees Can Put You in the Crosshairs of the IRS and DOJ for […]

Tax Court Holds IRS Assessment of Trust Fund Recovery Penalty Invalid Where No Final Administrative Determination Issued

In Romano-Murphy v Commissioner, 152 T.C. No. 16 (2019), the United States Tax Court held that an IRS assessment of a Trust Fund Recovery Penalty under […]

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 […]