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 […]
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 […]