Daniel W. Layton has handled many cases filed in District Court. His District Court litigation, motion practice, and trial experience has resulted in the following opinions, among others:

Bagley v. United States – Federal District Court trial of a multimillion-dollar refund action involving first-impression issue of whether a qui tam relator’s prosecution of an action under the False Claims Act could constitute a trade-or-business activity. Reported in 963 F. Supp. 2d 982 (C.D. Cal. 2013); 112 A.F.T.R.2d 5166; 2013-2 U.S. Tax Cas. (CCH) P50,462; 2013 U.S. Dist. LEXIS 109801.

United States v. Comco et al – Federal District Court litigation of transferee and alter ego claims in a complex case arising from a tax shelter, which result favorable judgment of more than $350 million on settlement. Opinion on discovery motion published in Westlaw at 2009 WL 10672579 and Lexis Nexis at 2009 U.S. Dist. LEXIS 118336, (favorably reversed in subsequent review by district court).

United States v. JPMorgan Chase Bank, NA, – Federal District Court litigation resolved by trial on the papers concerning an action for failure to honor bank levy. Published at 2014-2 U.S. Tax Cas. (CCH) P50,411; 114 A.F.T.R.2d (RIA) 5729); 2014 U.S. Dist. LEXIS 113896

United States v. Gaylor – Federal District Court litigation resolved through successful motion work to obtain a civil injunction against issuance of false IRS Forms 1099 to federal judges and others. Trial court opinion published at 2009-2 U.S. Tax Cas. (CCH) P50,821; 108 A.F.T.R.2d (RIA) 5092; 2009 WL 10675981; 2009 U.S. Dist. LEXIS 131301 (C.D. Cal. 2011). Affirmed by the Ninth Circuit at 108 A.F.T.R.2d 5088; 441 Fed. Appx. 478; 2011 U.S. App. LEXIS 13492; 2011-2 U.S. Tax Cas. (CCH) P50,499 (9th Cir. 2011) (designated as unpublished by 9th Cir. but citable per Fed. R. App. P. 32.1).

Schuyler v. United States – Federal District Court litigation resolved through successful motion work involving jurisdiction of third party refund claims, resulting in the first published opinion on the issue in a court within the 9th circuit after Congress amended the statutory scheme. Published at 2012-1 U.S.T.C. ¶50,268, (Dec. 19, 2011), 2011 WL 7463964.

James Daniel v. United States – Federal District Court litigation resolved through successful motion work regarding jurisdictional requirements of a refund claim. Opinion published at 113 A.F.T.R.2d (RIA) 837 (C.D. Cal. 2013); 2013 WL 7873531.

United States v. McIntyre – Federal District Court litigation resolved through successful motion work to obtain a permanent injunction. Published at 105 A.F.T.R.2d (RIA) 2693; 2010 WL 890138 and 105 A.F.T.R.2d (RIA) 1568; 2010 U.S. Dist. LEXIS 32763 (on motion for reconsideration) (C.D. Cal. 2010).

Dissinger v. United States – Summary proceeding in Federal District Court resulting in dismissal of a petition to quash IRS civil summons issued to a third party. Affirmed by the Ninth Circuit at 543 Fed.Appx. 620; 2013 U.S. App. LEXIS 21565; 2013-2 U.S. Tax Cas. (CCH) P50,570; 112 A.F.T.R.2d (RIA) 6639 (9th Cir. 2013) (designated as unpublished by 9th Cir. but citable per Fed. R. App. P. 32.1).

United States v. Mixco – Order of permanent injunction obtained in Federal District Court. Published at 112 A.F.T.R.2d (RIA) 6938; 2013 WL 6987706.

Grant v. United States – Summary proceeding in Federal District Court resulting in dismissal of a petition to quash IRS Criminal Investigation Division summons issued to a third party. Published in Westlaw at 2012 WL 71718.

United States v. Viray – Federal District Court litigation resolved through successful motion work to obtain permanent injunction. Published at 109 A.F.T.R.2d (RIA) 956; 2012 WL 759884; 2012 U.S. Dist. LEXIS 41882 (C.D. Cal. 2012).

Aljundi v. United States – Federal District Court litigation resolved through successful motion work pertaining to the jurisdiction of a refund claim. Published at 112 A.F.T.R.2d (RIA) 7297 (C.D. Cal. 2013); 2013 WL 7121190.

United States v. Benice – Federal District Court litigation involving reduction of federal tax assessments to judgment and foreclosure. Published in Westlaw at 2010 WL 3996597 and in Lexis Nexis at 2012 U.S. Dist. LEXIS 65327.

United States v. Yee – Federal District Court litigation involving reduction of federal tax assessments to judgment and foreclosure, resolved by a summary judgment motion. Published in Westlaw at 2019 WL 3485483.

United States v. Joyce – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published in Lexis Nexis at 2013 U.S. Dist. LEXIS 65883.

Coatney v. IRS (In re Coatney) – Appeal to Federal District Court from U.S. Bankruptcy Court decided on motion. Published in Lexis Nexis at 2011 U.S. Dist. LEXIS 96727.

United States v. Harrington – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published in Lexis Nexis at 2013 U.S. Dist. LEXIS 53711.

United States v. Alexander – Order of injunction regarding the sale of certain plans. Published at 107 A.F.T.R.2d (RIA) 1793; 2011 U.S. Dist. LEXIS 79742 (C.D. Cal. 2011).

United States v. Giroud – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published at 108 A.F.T.R.2d (RIA) 6372; 2012 U.S. Dist. LEXIS 63446 (C.D. Cal. 2012).

United States v. Koester – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published in Lexis Nexis at 2012 U.S. Dist. LEXIS 53102.

United States v. Kalter – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published in Lexis Nexis at 2011 U.S. Dist. LEXIS 142601.

United States v. Jaha – United States v. Jaha, C.D. Cal. – Summary proceeding in Federal District Court arising from a petition to enforce IRS summons. Published in Lexis Nexis at 2011 U.S. Dist. LEXIS 118520.