Mr. Layton’s tax litigation and trial experience has resulted in at least 30 reported decisions in Tax Court, U.S. District Court, and the Ninth Circuit. His representative matters include:
Bagley v. United States – Trial of a multi-million 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 112 A.F.T.R.2d 5166 (C.D. Cal. 2013).
United States v. Comco et al – Litigation of transferee and alter ego claims in a complicated case arising from a tax shelter, resulting in a favorable judgment of more than $350 million.
Wilson v. Commissioner – Tax Court trial involving innocent spouse relief and scope and standard of review issues. Affirmed by the Ninth Circuit at 705 F.3d 980 (9th Cir. 2013)
Natkunanathan v. United States – Refund action involving issues of bad debt loss and statute of limitations. Affirmed by the Ninth Circuit at 110 A.F.T.R.2d 5201 (9th Cir. 2013).
United States v. Trunzo – Criminal matter involving use of bank records and specific-items method of proof by government to support false tax return charge.
McGrady v. Commissioner – Successfully obtained summary judgment in Tax Court case involving deductions claimed for intellectual property.
Pacheco v. Commissioner – Tax Court trial involving innocent spouse relief and res judicata issues. Reported at T.C. Summary Opinion 2007-125.
United States v. Gaylor – Civil injunction case involving false IRS Forms 1099. Affirmed by the Ninth Circuit at 108 A.F.T.R.2d 5088 (2011).
For more on Daniel Layton's Federal District Court experience, click here.
For more on Daniel Layton's Tax Court experience, click here.