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  • Tax Publications
    • Taxation Of Medical Marijuana Dispensaries (Part 2 of 3)
    • The IRS has Released Recommendations in Two Cases in an Actions Relating to Court Decisions Document Released in The Internal Revenue Bulletin
    • U.S. Officials Accuse IRS of Digital Espionage and Fourth Amendment Violations in Criminal Tax Investigations
    • Why Stolen Identity Refund Fraud is the IRS’s Biggest Problem, and What Can Be Done About It
    • Why Stolen Identity Refund Fraud is the IRS’s Biggest Problem, and What Can Be Done About It (Part 2 of 3)
    • Why Stolen Identity Refund Fraud is the IRS’s Biggest Problem, and What Can Be Done About It (Part 3 of 3)
    • Taxation of Medical Marijuana Dispensaries (Part 3 of 3)
    • Taxation Of Medical Marijuana Dispensaries
    • Editor’s Note, California Journal of Tax Litigation (May 2013 Ed.)
    • Editorial Comment US Sentencing Commission Amendments
    • Note From the Editor – California Journal of Tax Litigation
    • Message from the Chair, California Journal of Tax Litigation (Feb. 2015 Ed.)
    • Tax-Exempt Mortgage Bonds: A Way to Alleviate the Self-Inflicted Damage Caused by CalHFA’s Reading of IRC Section 143
  • Interesting Tax Opinions
    • NICHELLE G. PEREZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • ROBERT I. REDISCH AND PAMELA A. REDISCH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • FREEDOM FROM RELIGION FOUNDATION, INC. v. LEW
    • RICHARD D. ESCALANTE AND BARBARA J. ESCALANTE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • ILM 201525010
    • Voss v. Commissioner
    • ABC BEVERAGE CORPORATION v. UNITED STATES OF AMERICA
    • CCA 201427016
    • CCA 201436049
    • ALVAN L. BOBROW AND ELISA S. BOBROW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • PHILIP D. LONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • SABINA LOVING, ET AL., APPELLEES v. INTERNAL REVENUE SERVICE, ET AL., APPELLANTS
    • FRANK ARAGONA TRUST, PAUL ARAGONA, EXECUTIVE TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
    • Fredric Allen, et al., Plaintiffs, v. United States of America, et al., Defendants
    • United States of America, Appellee, v. Leona M. Helmsley, Joseph v. Licari and Frank J. Turco, Defendants
    • UNITED STATES, Petitioner v. Gary WOODS
    • WELLS FARGO & CO. v. U.S, 112 A.F.T.R.2d 2013-5380, 2013-1 USTC P 50,368
    • BANK OF NEW YORK MELLON CORP, Petitioner v. COMMISSIONER of INTERNAL REVENUE, Respondent
    • BMW OF NORTH AMERICA, INC., Plaintiff, v. UNITED STATES of America, Defendant
    • BURIEN NISSAN, INC., et al.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • FRONTIER CHEVROLET CO., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent, 116 T.C. No. 23
    • WILLIE NELSON MUSIC COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
    • CHEMTECH ROYALTY ASSOCIATES, L.P., by DOW EUROPE, S.A., as Tax Matters Partner v. UNITED STATES of America.
    • HOWARD PONTIAC–GMC, INC., d.b.a. Bob Howard Automall, Petitioner v. COMMISSIONER
    • UNITED STATES of America, Appellee, v. Joseph D. NUNAN, Jr., Defendant-Appellant
    • UNITED STATES v. CAPONE
    • UNITED STATES of America, v. Darryl STRAWBERRY and Eric Goldschmidt, Defendants
    • UNITED STATES of America v. Spiro T. AGNEW
    • 149 T.C. No. 7 AVRAHAMI v. COMMISSIONER
    • Coal Property Holdings, LLC, Coal Land Manager, LLC, Tax Matters Partner v. Commissioner.
  • IRS and Tax FAQS
    • What Are Tax Return Preparer Penalties?
    • Where and When Can I Sue the IRS For My Tax Refund or to Appeal an Audit?
    • How Long Should I Keep My Tax Return?
    • How Long Do I Have to Ask the IRS For A Refund?
    • What Should I Do If I Receive an IRS Summons Form 2039?
    • How Far Back Can the IRS Audit / What is the IRS Audit Statute of Limitations?
    • What is a Federal Tax Prosecutor?
    • How much power does a Federal Tax Prosecutor have?
    • Why Hire a Tax Attorney?
    • How Long Does the IRS Have To Collect?
    • What is the IRS Office of Criminal Investigation (CI)?
    • How Can I Get a Lien For Someone Else’s Taxes Released From My Property in Escrow?
    • What Is Employment Tax Pyramiding?
    • Where Can I File A Quiet Title Action to Challenge A Tax Lien on My Real Property?
    • Where to send my Power of Attorney (POA)?
    • What is FATCA?
    • What is the Foreign Account Tax Compliance Act Timeline?
    • What Are Tax Deductible Business Expenses?
    • When Are Tax Preparation and Tax Attorney Fees Deductible?
    • What Is A “Nominee” Or “Alter Ego” Tax Lien?
    • What Is The Trust Fund Recovery Penalty?
    • What Is An Offer-In-Compromise?
    • What Should I Do If Someone Stole My Identity to File A False Tax Return?
    • What Is an IRS Identity Protection PIN?
    • What Is Innocent Spouse Relief from Federal Taxes?
    • Why Does the IRS Deny Real Estate Losses as “Passive”/What is a “Real Estate Professional” under Tax Law?
    • What is the List of Countries with Shared Banking Agreements with the US?
    • What Foreign Banks have been Blacklisted by the IRS?
    • What is the Office of Professional Responsibility (OPR)?
    • What is a TraCE investigation?
    • What Happens in an Examination Appeals Hearing? Working with IRS Office of Appeals.
    • Fact Sheet: IRS Clarifies Office of Appeals Policies (Updated October 1, 2016)
    • What is an IRS summons?
    • How Are Criminal Tax Investigations Initiated?
  • Speaking Engagements
  • Common IRS Tax Forms
  • Newsletter
  • Archive IRS Tax News
    • July 11 Marks End of Early Registration for Dallas IRS Tax Forum
    • Security Summit Launches Education Campaign Aimed at Tax Pros; Warns Against Phishing Epidemic with “Don’t Take the Bait” series
    • IRS Launches Country-by-Country Reporting Pages on IRS.gov
    • IRS Launches 2017 Summertime Tax Tip Program
    • Electronic Tax Administration Advisory Committee Issues 2017 Annual Report
    • National Taxpayer Advocate Reviews Filing Season and Identifies Priority Areas and Challenges in Mid Year Report to Congress
    • IRS Cautions Taxpayers to Watch for Summertime Scams
    • Security Summit Warns of New Phishing Email Targeting Tax Pros
    • IRS Website Provides Tools to Help Small Businesses Understand Employment Taxes
    • IRS Now Accepting Renewal Applications for ITINs Set to Expire by End of 2017
    • Orlando IRS Tax Forum Registration Deadline is June 27
    • IRS Warns of New Phone Scam Involving Bogus Certified Letters; Reminds People to Remain Vigilant Against Scams, Schemes this Summer
    • IRS Continues to Expand Taxpayer Services; Adds New Features to Taxpayers Online Account
    • Taxpayers Abroad Must File by June 15; Extensions Available; New Filing Deadline Now Applies to Foreign Account Reports
    • Interest Rates Remain the Same for the Third Quarter of 2017
    • IRS Approves First Group of Certified Professional Employer Organizations; More Expected in Coming Months
    • For Letter Rulings and Similar Requests: Electronic Payment of User Fees Starts June 15; Replaces Paying by Check
    • Spring 2017 Statistics of Income Bulletin Now Available
    • IRS Tax Forum ‘Early Bird’ Registration Ends May 31; Tax Pros Can Save By Registering Early
    • Prepared Remarks of John A. Koskinen Commissioner Internal Revenue Service Before the Council for Electronic Revenue Communications Enhancement Arlington, VA May 18, 2017
    • IRS Announces Three New Members for Advisory Committee on Tax Exempt and Government Entities
    • For Hurricane Preparedness Week: IRS Offers Tips to Taxpayers Preparing for Hurricanes, Floods and Other Natural Disasters
    • Many Tax-Exempt Organizations Must File by May 15; Do Not Include Social Security Numbers or Personal Data
    • IRS: Home Office Deduction Often Overlooked by Small Business Owners
    • Registration Now Open for the 2017 IRS Nationwide Tax Forums
    • IRS Accepting Applications for 2018 Low Income Taxpayer Clinic Grants
    • Small Business Week Reminder: Startups Can Choose New Option for Claiming Research Credit
    • IRS Sees Millions of Tax Returns Last Days of Tax Filing Season
    • IRS Issues Tips on What to do After the Tax-Filing Deadline
    • IRS Seeks Applications for Information Reporting Program Advisory Committee
    • IRS Provides Tips on Determining If It’s Really The IRS At Your Door
    • IRS Reminds Those with Foreign Assets of U.S. Tax Obligations; New Filing Deadline Now Applies to Foreign Account Reports
    • Some Taxpayers Get Extensions without Asking; Taxpayers Abroad, in Combat Zones and Disaster Areas Qualify
    • IRS Alerts Taxpayers with Limited English Proficiency of Ongoing Phone Scams; Urges Caution Before Paying Unexpected Tax Bills
    • Written Testimony of John A. Koskinen Before the Senate Finance Committee on the 2017 Filing Season and IRS Operations April 6, 2017
    • Prepared Remarks of John A. Koskinen Before the National Press Club Washington, DC April 5, 2017
    • Private Collection of Some Overdue Federal Taxes Starts in April; Those Affected Will Hear First From IRS; IRS Will Still Handle Most Tax Debts
    • For Small Business Startups, IRS Explains New Option for Claiming Research Credit; Option Still Available for Those That Already Filed
    • IRS Releases FY 2016 Data Book Showing Range of Tax Data, Including Service and Enforcement Changes
    • IRS Reminds Seniors to Remain on Alert to Phone Scams during Tax Season
    • IRS, States and Tax Industry Warn of Last-Minute Email Scams
    • IRS Seeks Applications for Electronic Tax Administration Advisory Committee
    • Program Report and 2017 Publication 4134, Low Income Taxpayer Clinic List
    • Interest Rates Remain the Same for the Second Quarter of 2017
    • IRS Makes Approved Form 1023-EZ Data Available Online
    • Security Summit Alert: Tax Professionals Warned of New Scam to “Unlock” Their Tax Software Accounts
    • Don’t Take the Bait, Step 1: Avoid Spear Phishing Emails
    • Don’t Take the Bait, Step 1: Avoid Spear Phishing Emails
    • Don’t Take the Bait, Step 2: Be Alert to Account Takeover Tactics
    • Taxpayers Should Review Their Withholding; Avoid Having Too Much or Too Little Federal Income Tax Withheld
    • IRS Office of Appeals Pilots Virtual Service
    • Don’t Take the Bait, Step 3: Security Summit Safeguards Help Protect Individuals; Renew Focus on Curbing Data Breaches and Business Identity Theft
    • National Harbor IRS Tax Forum Registration Deadline is Aug. 8
    • Don’t Take the Bait, Step 4: Defend against Ransomware
    • Security Summit Alert: Tax Pros Warned of New Scam to Steal Their Passwords
    • Don’t Take the Bait, Step 5: Prevent Remote Access Takeover Attacks
    • IRS Begins Issuing Notices to Taxpayers whose ITINs Expire by End of 2017
    • IRS Reminds Truckers: For Most, Highway Use Tax Return Is Due Aug. 31; E-file Is a Convenient Filing Option
    • Don’t Take the Bait, Step 6: Watch Out for the W-2 Email Scam
    • IRS Seeks Applications for Advisory Committee for the Tax Exempt and Government Entities Division
    • Don’t Take the Bait, Step 7 Protect e-Services Accounts, EFINs
    • Don’t Take the Bait, Step 8: How to Start Protecting Clients, Businesses from Cybersecurity Threats
    • IRS Gives Tax Relief to Victims of Hurricane Harvey; Parts of Texas Now Eligible; Extension Filers Have Until Jan. 31 to File
    • IRS Issues Urgent Warning to Beware IRS FBI Themed Ransomware Scam
    • Beware of Fake Charity Scams Relating to Hurricane Harvey
    • Retirement Plans Can Make Loans, Hardship Distributions to Victims of Hurricane Harvey
    • IRS Waives Diesel Fuel Penalty Due to Hurricane Harvey
    • IRS Provides Special Relief to Encourage Leave-Based Donation Programs for Victims of Hurricane Harvey
    • Don’t Take the Bait, Step 9: Make Data Security an Everyday Priority; Key Steps Can Help
    • As Hurricane Irma Threatens, IRS Urges Taxpayers to Prepare for Hurricanes, Floods and Other Disasters
    • IRS Announces Five New Members for the Electronic Tax Administration Advisory Committee
    • IRS Plans to Issue Regulations Clarifying Limitations on Carried Interest
    • Tax Time Guide: Try Money-Saving IRS Free File
    • Phishing Schemes Make IRS ‘Dirty Dozen’ List of Tax Scams for 2018; Individuals, Businesses, Tax Pros Urged to Remain Vigilant
    • Phone Scams Pose Serious Threat; Remain on IRS ‘Dirty Dozen’ List of Tax Scams
    • Tax Time Guide: Use IRS.gov to Find Qualified Tax Professionals
    • Interest Rates Increase for the Second Quarter of 2018
    • IRS Settlement of Syndicated Conservation Easement Transaction in Cases Docketed Before the U.S. Tax Court Additional Information
    • Chief Counsel Notice: Syndicated Conservation Easement (SCE) transaction: Partnership: Settlement
    • IR-2021-151,Internal Revenue Service, (Jul. 14, 2021)
  • California IRS Attorney FAQS
• IRS Tax News
  • Treasury Inspector General for Tax Administration (TIGTA) Report: Review of the Internal Revenue Service’s Process to Address Violations of Tax Law by Its Own Employees (Reference Number: 2015-10-002), (May 7, 2015)
  • Letter from Sen. Grassley to IRS Commissioner Koskinen Regarding Termination of IRS Employees
  • Proposed Reliance Regs Qualified Opportunity Funds, Zones and Businesses Internal Revenue Service,(Apr. 17, 2019)
  • IRS Revenue Ruling 2019-24
• Tax Attorney-Los Angeles, Orange County/Irvine, Riverside
• Former IRS Trial Attorneys, California FTB Attorneys, Assistant US Attorneys and Federal Tax Prosecutors
  • Joseph P. Wilson
    • The Newport Beach Tax Attorney
    • Joseph P. Wilson – Federal Court Tax Experience
    • Joseph P. Wilson – Bar Admissions
    • Joseph P. Wilson – Activities and Involvement
    • Joseph P. Wilson – Recognition, Awards, and Honors
    • Joseph P. Wilson – Sample Reported Decisions
• Wilson Tax Law Group – Sample Federal Tax Litigations
  • Villela-Wilcox v. Commissioner of Internal Revenue
  • Powers, et. al. v. Commissioner of Internal Revenue
  • Boparai v. Commissioner of Internal Revenue
  • Garza v. Commissioner of Internal Revenue
  • Hough v. Commissioner of Internal Revenue
  • Pacheco v. Commissioner of Internal Revenue
  • Torres, et. al. v. Commissioner of Internal Revenue
  • Wilson v. Commissioner of Internal Revenue
  • Jorgensen, et. al. v. Commissioner of Internal Revenue
  • In The Matter of Tax Liabilities of: John Does, Norwegian taxpayers holding East West Bank Card, et. al.
  • United States of America v. Comco Management Corp., et al.
  • United States of America v. JPMorgan Chase Bank NA
  • Schuyler v. United States
• Honors & Award Badges
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• Fareedeh Wilson
• San Diego IRS Tax Forum Registration Deadline is Aug. 29; Final Tax Forum for 2017
• Delinquent FBAR Submission Procedures
• Cryptocurrency Taxation Defense
• Joseph P. Wilson Named to Top 3 Tax Attorney List for Newport Beach, California
• Tax Blog
• IRS Frequently Asked Questions on Virtual Currency Transactions
• IPT Tax Symposium White Paper Property Taxes
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• State Public Health Officer designated list of “Essential Critical Infrastructure Workers”
• Legal Disclaimer
• Los Angeles Offers Tax Penalty Amnesty Program
• List of Countries with U.S. Exchange of Information Agreements
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