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 […]
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, […]
When can IRS levy bank account

When Can the IRS Levy or Garnish?

When can the IRS levy or garnish your wages or bank accounts? In general, the IRS can issue a levy after the tax is assessed (meaning […]
Full payment rule tax penalties interest

Does the Full Payment Rule in District Court Tax Refund Suits Include Tax, Penalties, and Interest?

Does the Full Payment Rule in Federal District Court Tax Refund Suits Include Tax, Penalties, and Interest? It has long been the law that, before a […]