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 […]

Opinion of the Day: Seventh Circuit Judge Richard Posner Sits as District Court Judge in Criminal Tax Case

While I was a law student at the University of Chicago, I was fortunate enough to have Richard Posner, one of the more well known federal […]

Tax Court Rejects Frivolous Filing Penalty for Taxpayer Invoking the Fifth Amendment in Tax Return

On November 6, 2015, the United States Tax Court issued its opinion in Youssefzadeh v. Commisioner, Docket No. 14868-14L, in which it held that the taxpayer […]

Tax Court Issues Opinion in Sumner Redstone v. Commissioner, T.C. Memo. 2015-237

The United States Tax Court recently released its opinion in the Sumner Redstone case.  The case is notable not just because Redstone is a media magnate, […]

US Tax Court Sides With Whistleblower in Award Case

In June, the Tax Court issued its opinion in 21276-13W v. Commissioner, 144 T.C. No. 15 (2016).  This is one of the better written case opinions […]

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]

Austin v. Commissioner, T.C. Memo. 2017-69

The Untied States Tax Court issued its opinion in Austin v. Commissioner, T.C. Memo. 2017-69, on April 24, 2017.  The full text of the opinion is […]