Orange County Tax Attorney Blog

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 […]

Recent Conviction Illustrates Connection Between Use of Nominees and Tax Evasion

A Recent Conviction in Hawaii’s U.S. District Court Illustrates How the Use of Nominees Can Put You in the Crosshairs of the IRS and DOJ for […]

Tax Court Holds IRS Assessment of Trust Fund Recovery Penalty Invalid Where No Final Administrative Determination Issued

In Romano-Murphy v Commissioner, 152 T.C. No. 16 (2019), the United States Tax Court held that an IRS assessment of a Trust Fund Recovery Penalty under […]

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 […]