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Frivolous Arguments

Tax Court imposes $20,000 excess litigation costs against attorney for frivolous suit

Tax Court imposes $20,000 excess litigation costs against attorney for frivolous suit

Best, TC Memo 2016-32 In a supplemental opinion, the Tax Court has ordered an attorney to pay nearly $20,000 in excess litigation costs under Code Sec. 6673(a)(2) for unnecessarily bringing and prolonging a collection due process case. The Court found that the attorney acted in bad faith by bringing the case in the first place […]

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Supreme Court won’t review case on IRS’s designation of hearing request as frivolous

Supreme Court won’t review case on IRS’s designation of hearing request as frivolous

Ryskamp, (CA DC 8/14/2015) 116 AFTR 2d 2015-5614, cert denied 1/11/2016 The Supreme Court has declined to review a decision of the Court of Appeals for the District of Columbia Circuit which held that Code Sec. 6330(g)’s prohibition of further review of frivolous requests for a collection due process (CDP) hearing does not preclude the […]

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Tax Court upholds Appeals’ determination that hearing request was frivolous & dismisses case

Tax Court upholds Appeals’ determination that hearing request was frivolous & dismisses case

Buczek, (2014) 143 TC No. 161 The Tax Court has held that it has jurisdiction to determine whether a taxpayer seeking judicial review under Code Sec. 6330(d)(1) has raised a non-frivolous issue and has agreed with Appeals that no non-frivolous issues were raised. Accordingly, it upheld Appeals’ determination to disregard the taxpayer’s hearing request and […]

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Court rules that prior law frivolous tax return penalty survives taxpayer’s death

Court rules that prior law frivolous tax return penalty survives taxpayer’s death

Molen, (DC CA 5/21/2014) 113 AFTR 2d ¶ 2014-842. A district court has held that the pre-Apr. 3, 2007 version of the Code Sec. 6702(a) frivolous tax return penalty meets the Supreme Court’s test of being a civil penalty and therefore it survives the taxpayer’s death. Note: Although the court explicitly limited its holding to […]

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Court Issues Order Barring Michigan Tax Preparer from Preparing Federal Tax Returns for Others

Court Issues Order Barring Michigan Tax Preparer from Preparing Federal Tax Returns for Others

Per the DOJ Press Release, the U.S. District Court for the Eastern District of Michigan has issued an order permanently barring Nataki Davis, (formerly known as Nataki Barnes), a Southfield, Mich., tax preparer, from preparing federal tax returns for others for a period of five years, the Justice Department announced today (June 7). The court […]

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Six Sentenced to Prison in Florida for Federal Tax Crimes

Six Sentenced to Prison in Florida for Federal Tax Crimes

As reported by the DOJ press release, six individuals have been sentenced to federal prison by U.S. District Judge William P. Dimitrouleas for filing false claims for tax refunds, announced Kathryn Keneally, Assistant Attorney General for the Justice Department’s Tax Division, Wifredo A. Ferrer, U.S. Attorney for the Southern District of Florida, and Jose A. […]

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What happens when a real attorney tries tax protest arguments?

What happens when a real attorney tries tax protest arguments?

Editor’s Note:  An interesting article entitled “What happens when a real attorney tries tax protest arguments?” caught my eye, and I’ve attached a link to the reported case of Worsham v. Commissioner, T.C. Memo. 20012-209, in the U.S. Tax Court.  Here’s the article: Arguments that you don’t have to really pay federal income taxes never […]

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IRS Workers With Convictions

IRS Workers With Convictions

Editor’s Note:  after blogging on “Tax Court Alert: Civil Fraud Penalty Assessed Against IRS Tax Compliance Officer,” I came across another article, published some time ago by Forbes entitled “IRS Workers with Convictions,” which reported on the tax agency dealing with rogue employees in everything from celebrity snooping to extortion.  What brought that to mind […]

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Federal Court Shuts Down Florida Tax Return Preparers

Federal Court Shuts Down Florida Tax Return Preparers

In another in a long line of cases won by the Government, the Department of Justice announced that a “Federal Court Shuts Dow.Florida Tax Return Preparers.”  Here’s the announcement. A federal court in Miami has permanently barred Sharon Angulo and Claudia Zuloaga, both of Miami, from preparing federal tax returns for others, the Justice Department […]

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Arizona Tax Defier Sentenced to Nine Years in Prison for Fraud and Tax Conspiracy

Arizona Tax Defier Sentenced to Nine Years in Prison for Fraud and Tax Conspiracy

Richard Kellogg Armstrong, 77, of Prescott, Ariz., was sentenced August 10, 2012 by U.S. District Court Judge Robert E. Blackburn to 108 months in prison followed by three years of supervised release.  Judge Blackburn ordered the sentence to run con secutively to the 660 day prison term and $1,021,500 of fines cumulatively imposed upon Armstrong […]

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Lauryn Hill: Plea Agreement Reached for Criminal Tax Problems – – Another lucky entertainer with issues, . . .

Lauryn Hill:  Plea Agreement Reached for Criminal Tax Problems – – Another lucky entertainer with issues, . . .

Editor’s Note:  many times celebrities seem to get caught up in the tax system, whether they owe taxes or worse, get indicted for criminal tax fraud.  The general public is often left scratching their heads, saying why are those folks any different than us?  Lauryn Hill, the entertainer, is no exception.  In the Department of […]

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IRS Releases the Dirty Dozen Tax Scams for 2012

IRS Releases the Dirty Dozen Tax Scams for 2012

IRS Releases the Dirty Dozen Tax Scams for 2012 IRS YouTube Videos: Dirty Dozen: English | Spanish | ASL WASHINGTON –  The Internal Revenue Service recently issued its annual “Dirty Dozen” ranking of tax scams, reminding taxpayers to use caution during tax season to protect themselves against a wide range of schemes ranging from identity […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney