Orange County Tax Attorney Blog

Letting the Door Hit You in the Tax on the Way Out: IRS Issues Relief Procedures for Certain Persons Who Relinquished US Citizenship But Wish to Complete Tax Compliance

In September of 2019, the IRS Issued Relief Procedures for Certain Persons Who Relinquished Their United States Citizenship But Who Were Out of Tax Compliance. The […]

What Is the Standard for Admission of Evidence in a Hearing on Revocation of Probation or Supervised Release?

What Is the Standard for Admission of Evidence in a Hearing on Revocation of Supervised Release or Probation? Because the Federal Rules of Evidence do not […]

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 […]

Before the Tax Season Starts, A Reminder to Choose Your Return Preparer Carefully

Earlier this month, the DOJ issued a press release that buried the lead, titled, “Former eBAY Manager Pleads Guilty To Stealing More Than $200,000 In IRS […]

Letter 5105 Being Sent to Select Return Preparers in January – How Can You Respond?

As a tax controversy attorney, although I don’t prepare returns myself, I try and stay in touch with issues affecting return preparers, CPAs, and enrolled agents. […]

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. […]

Celebrity Sightings and Tax Monologues

Perhaps I should find it a bit embarrassing to admit, but I have always gotten a kick out of celebrity sightings.  Of course, having lived in […]

Ohio Supreme Court Limits Reach of Cleveland to Tax Professional Athletes

On April 30, 2015, the Ohio Supreme Court issued an interesting opinion in Hillenmeyer v. Cleveland Bd. of Rev., Slip Opinion No. 2015-Ohio-1623.  In that case, the […]

Criminal Tax Practitioner’s Update: Sentencing Guidelines Updated to Account for Inflation

On April 30, 2015, the United States Sentencing Commission issued Amendments to the Sentencing Guidelines.  Of significance to criminal tax attorneys like myself, the amounts on […]

City of Newport Beach Proposes $282 Milllion Budget

The OC Register recently reported on the proposed project and operating budget for the City of Newport Beach. That article can be found here.  The proposed […]

2016 FBAR Still Due [Update – April 18], 2017, But With Option to Extend to October 15

[12/22/16 Update: FBAR Due April 15 each year, but April 18, 2017 for 2016 FBAR, and extension is automatic to October 15, 2017 – see post […]

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 […]

IRS Raking It In through Offshore Voluntary Disclosures, Encourages More OVDP

WARNING: Update 3/13/2018.  The IRS has announced the formal Offshore Voluntary Program discussed below will be closed on September 28, 2018.  For more, see our post […]