Orange County Tax Attorney Blog

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What is the Value of a JD/MBA? An Attorney’s Take on Dual Law and Business Degrees.

What is the Value of a JD/MBA? An Attorney’s Take on Dual Law and Business Degrees. Before and after law school, many people consider attending business […]

When Are Legal Fees Deductible as Employee Business Expenses?

When Are Legal Fees Deductible as Employee Business Expenses? In Guill v. Commissioner, 112 T.C. 325 (1999), the United States Tax Court succinctly explained the deductibility […]
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What Actions Extend the Length of the IRS’s Time to Collect?

What Actions Extend the Length of the IRS’s Time to Collect? Under the general rule, the IRS must collect taxes within 10 years of the date […]
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Does the IRS Have Discretion to Apply Lower FBAR Penalties?

Does the IRS Have Discretion to Apply Lower FBAR Penalties? On May 13, 2015, the IRS issued a memorandum to all IRS LB&I, SB/SE, and TE/GE […]

When Can I take Casualty Theft Losses On My Tax Return?

When Can I take Casualty Theft Losses On My Tax Return? Per 26 U.S.C. § 165(c) casualty loss deductions can be taken for theft.  Per IRS […]

The Limits of Waivers of Attorney Conflicts of Interest In Federal Criminal Cases

  The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance […]

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 […]