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 […]

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 […]