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  • Daniel Layton
  • January 10, 2019 01:36:39 AM
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Newport Beach tax attorney Daniel Layton defends Orange County clients in IRS and FTB audits & collections, criminal tax defense, tax fraud & evasion cases, FBAR penalty defense, and foreign account disclosures (e.g., streamlined procedures).

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    Palm Beach County Tax Return Preparer Sentenced to Prison for Filing False Returns and Theft of Government Funds

    The United States Department of Justice has issued a press release concerning the sentencing of a West Palm Beach tax return preparer. Paul Senat was sentenced […] The post Palm Beach County Tax Return Preparer Sentenced to Prison for Filing False Returns and Theft of Government Funds appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

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    The United States Department of Justice has issued a press release concerning the sentencing of a West Palm Beach tax return preparer. Paul Senat was sentenced by the Southern District of Florida to 90 months in prison for aiding and assisting in the preparation of false tax returns and theft of government funds.

    Per the press release:

    According to the evidence presented at trial, from at least 2012 to 2016, Paul Senat was the owner and operator of multiple tax return preparation businesses in Palm Beach and surrounding areas. Through the businesses, Senat falsified his clients’ returns by reporting fictitious business losses and education credits in order to fraudulently inflate their refunds.  Senat also stole a federal tax refund check worth nearly $10,000.

    A federal jury in Fort Lauderdale, Florida convicted Senat on Nov. 6, 2019.  Following the jury verdict, Senat was taken into custody.

    At sentencing, U.S. District Judge Rodolfo A. Ruiz found that Senat caused a tax loss of more than $3.5 million to the United States.

    In addition to the term of imprisonment, U.S. District Judge Ruiz ordered Senat to serve three years of supervised release and to pay $9,779 in restitution to the United States.

    According to the Tax Division’s Criminal Tax Manual, aiding and assisting in the preparation of false tax returns is charged under 26 U.S.C. §7206(2). The elements for a conviction under this statute are:

    1. Defendant aided or assisted in, procured, counseled, or advised the preparation or presentation of a document in connection with a matter arising under the internal revenue laws;
    2. The document was false as to a material matter;
    3. The act of the defendant was willful

    Theft of government funds is charged under Section 641 of Title 18 of the United States Code, 18 U.S.C. § 641. This section is titled “Embezzlement of Government Property” and the elements for a charge are listed below:

    1. a trust or fiduciary relationship between the defendant and the property owner;
    2. the property taken falls within the statute; i.e., it must be government property (see this Manual at 1643 for a discussion of the types of property which fall within this section);
    3. the property came into the possession or care of the defendant by virtue of his employment;
    4. the property belonged to another, in this case the United States;
    5. the defendant’s dealings with the property constituted a fraudulent conversion or appropriation of it to his own use; and
    6. the defendant acted with the intent to deprive the owner of the use of this property.

    The “Tax Table” provides that tax losses of more $3.5 million dollars, before considering other relevant factors or characteristics, fall under Offense Level 24 because it is more than $3.5 million and less than $9.5 million. According to the “Sentencing Table”, an Offense Level of 24 typically carries with it a sentence of between 51 and 63 months.  

    All persons who are merely charged with crimes are presumed innocent until proven guilty. Furthermore, sentences can vary depending on several factors which vary from person to person. This blog post does not implicitly or explicitly suggest there is basis to the prosecuting agency’s allegations or take any position on the strengths or weaknesses of the government’s positions.

    Posted on 02/26/2020 by Benjamin Tu

    The post Palm Beach County Tax Return Preparer Sentenced to Prison for Filing False Returns and Theft of Government Funds appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


    Portland Tax Return Preparer Sentenced to Prison for Preparing False Returns

    The United States Attorney’s Office for the District of Maine has issued a press release for the sentencing of a tax return preparer located in Portland, […] The post Portland Tax Return Preparer Sentenced to Prison for Preparing False Returns appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

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    The United States Attorney’s Office for the District of Maine has issued a press release for the sentencing of a tax return preparer located in Portland, Maine. The individual in question, Ashraf Eldeknawey, had been charged with preparing false tax returns.

    Per the press release:

    U.S. District Judge D. Brock Hornby sentenced Ashraf Eldeknawey, 46, to six months in prison and one year of supervised release. Judge Hornby also ordered Eldeknawey to pay $97,191 in restitution to the IRS. Eldeknawey pleaded guilty on August 14, 2019.

    According to court documents and information presented in court, Eldeknawey operated a tax return preparation business located inside the Ahram Halal Market in Portland from 2015 to 2018. He prepared fraudulent tax returns for clients on which he reported self-employment income that they did not earn. As a result, the clients received tax refunds to which they were not entitled. Eldeknawey also filed a 2014 tax return for himself on which he overstated the expenses associated with a painting business he operated.

    Per the Tax Division’s Manual, preparing false tax returns is charged under 26 U.S.C. § 7206(2). The elements for this charge are that:

    1. Defendant aided or assisted in, procured, counseled, or advised the preparation or presentation of a document in connection with a matter arising under the internal revenue laws;
    2. The document was false as to a material matter;
    3. The act of the defendant was willful

    As previously stated, the defendant has been sentenced to six months in prison, sentenced to one year of supervised release, and ordered to pay $97,191 in restitution to the IRS. Before considering other relevant factors or characteristics, the Sentencing Table in the United States Sentencing Guidelines provides sentences of six months for Offense Levels of 10 or below. An Offense Level of 10 is designated for activities that incur tax losses of more than $6,500, and less than $15,500 based on the “Tax Table” found in USSG 2T4.1.

    All persons who are merely charged with crimes are presumed innocent until proven guilty. Furthermore, sentences can vary depending on several factors which vary from person to person. This blog post does not implicitly or explicitly suggest there is basis to the prosecuting agency’s allegations or take any position on the strengths or weaknesses of the government’s positions.

    Posted on 02/04/2020 by Benjamin Tu

    The post Portland Tax Return Preparer Sentenced to Prison for Preparing False Returns appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


    Utah Tax Return Preparers Indicted for Tax Crimes

    A recent press release from the U.S. Department of Justice announced that three Utah based tax return preparers were indicted for tax crimes. Sergio, Alissa, and […] The post Utah Tax Return Preparers Indicted for Tax Crimes appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

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    A recent press release from the U.S. Department of Justice announced that three Utah based tax return preparers were indicted for tax crimes. Sergio, Alissa, and David Sosa were all charged with conspiracy to defraud the United States.

    Per the press release:

    Sergio Sosa was also charged with one count of tax evasion, and he and his children were also each charged with one count of corruptly endeavoring to obstruct the administration of the internal revenue laws.

    According to the indictment, Sosa owned and operated Sergio Central Latino (SCL), a tax return preparation business in Orem, Utah, where both Alissa and David worked.  From 2003 through 2017, Sosa allegedly did not timely file his personal tax returns and after multiple audits, the Internal Revenue Service (IRS) determined that he owed more than $750,000 in unpaid taxes. When the IRS began collection efforts, Sosa and his children allegedly agreed to obstruct IRS collection of the outstanding taxes by hiding Sosa’s personal assets, residential properties, and by titling SCL in the children’s names.

    The indictment also alleges that when the IRS suspended SCL’s ability to electronically file client tax returns due to Sosa’s unpaid taxes, David Sosa changed SCL’s business name and obtained electronic filing authorization in a third party’s name. It is further alleged that Alissa Sosa falsely represented to the IRS that she owned a residence that was, in fact, her father’s, and that she withdrew funds from an account that she knew had been levied by the IRS. As of 2019, Sosa allegedly owes more than $1.1 million in taxes, penalties, and interest.

    Per the Criminal Resource Manual, conspiracy to defraud the United States ­­­is charged under 18 U.S.C. § 371 stating “[i]f two or more persons conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose”. The factors for whether an activity defrauds the government under 18 U.S.C. § 371 are laid out by the Criminal Resource Manual as the following:

    1.  They cheat the government out of money or property;
    2. They interfere or obstruct legitimate Government activity; or
    3. They make wrongful use of a governmental instrumentality.

    According to the Tax Division’s manual, the elements of a charge for tax evasion are

    1. An affirmative act constituting an attempt to evade or defeat a tax or the payment thereof. Sansone v. United States, 380 U.S. 343, 351 (1965); Spies v. United States, 317 U.S. 492, 497-99 (1943).
    2. An additional tax due and owing. Boulware v. United States, 552 U.S. 421, 424 (2008); Sansone v. United States, 380 U.S. 343, 351 (1965); Lawn v. United States, 355 U.S. 339, 361 (1958).
    3. Willfulness. Cheek v. United States, 498 U.S. 192, 193 (1991); United States v. Pomponio, 429 U.S. 10, 12 (1976); United States v. Bishop, 412 U.S. 346, 358-59 (1973); Sansone v. United States, 380 U.S. 343, 351 (1965); Holland v. United States, 348 U.S. 121, 124, 139 (1954).

    Finally, the three family members were charged with obstructing the administration of IRS laws. This charge is outlined under 26 U.S.C. §7212(a), better known as the “Omnibus Clause”. The Tax Division’s Manual states that in order to prove that a violation has occurred, the government must prove beyond a reasonable doubt that the defendant has in any way

    1. Corruptly
    2. Endeavored
    3. To Obstruct or Impede the due administration of the Internal Revenue Code

    The press release continues to discuss possible sentences for this case:

    “If convicted, the Sosas each face a statutory maximum sentence of five years in prison for the conspiracy charge and three years in prison for corruptly endeavoring to obstruct the administration of the internal revenue laws. Sergio Sosa faces an additional five years in prison for tax evasion. The Sosas also face a period of supervised release, restitution, and monetary penalties.”

    All persons who are merely charged with crimes are presumed innocent until proven guilty. Furthermore, sentences can vary depending on several factors which vary from person to person. This blog post does not implicitly or explicitly suggest there is basis to the prosecuting agency’s allegations or take any position on the strengths or weaknesses of the government’s positions.

    Posted on 02/04/2020 by Benjamin Tu

    The post Utah Tax Return Preparers Indicted for Tax Crimes appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


    Nevada Return Preparer Sentenced to More Than Three Years in Prison for Tax Crimes

    The United States Department of Justice announced that Michael A. Sandoval, a return preparer located in Las Vegas, Nevada, was sentenced for tax evasion, aiding and […] The post Nevada Return Preparer Sentenced to More Than Three Years in Prison for Tax Crimes appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

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Tax Attorney Orange County

    The United States Department of Justice announced that Michael A. Sandoval, a return preparer located in Las Vegas, Nevada, was sentenced for tax evasion, aiding and assisting in the preparation and filing of a false tax return, and making and subscribing a false tax return. He was sentenced to three years and four months of imprisonment.

    Per the press release:

    According to court documents and statements made in court, Michael A. Sandoval provided payroll and tax preparation services for individuals and companies through his Las Vegas business Nevada Financial Solutions Inc. (NFS). When two of Sandoval’s clients provided NFS with $471,178 in payments to be forwarded to the Internal Revenue Service (IRS) as money due for their quarterly employment taxes, Sandoval did not provide those payments to the IRS, but instead spent the funds for his personal benefit. At NFS, Sandoval also filed and caused the filing of false individual income tax returns for a substantial number of clients by reporting fraudulent deductions, including false Schedule C business losses, charitable contributions, and state and local tax deductions. These fraudulent deductions caused a tax loss of over $2.8 million. On his own individual tax returns, Sandoval fraudulently understated his income from NFS for the years 2010 through 2017, causing an additional tax loss of $100,138. In total, Sandoval caused a tax loss totaling $3,425,654 to the IRS.

    Sandoval previously pleaded guilty to one count each of tax evasion, aiding and assisting in the preparation and filing of a false tax return, and making and subscribing a false tax return.

    Per the Tax Division’s manual, the elements of a charge for tax evasion are:

    1. An affirmative act constituting an attempt to evade or defeat a tax or the payment thereof. Sansone v. United States, 380 U.S. 343, 351 (1965); Spies v. United States, 317 U.S. 492, 497-99 (1943).
    2. An additional tax due and owing. Boulware v. United States, 552 U.S. 421, 424 (2008); Sansone v. United States, 380 U.S. 343, 351 (1965); Lawn v. United States, 355 U.S. 339, 361 (1958).
    3. Willfulness. Cheek v. United States, 498 U.S. 192, 193 (1991); United States v. Pomponio, 429 U.S. 10, 12 (1976); United States v. Bishop, 412 U.S. 346, 358-59 (1973); Sansone v. United States, 380 U.S. 343, 351 (1965); Holland v. United States, 348 U.S. 121, 124, 139 (1954).

    In regards to aiding and assisting in the preparing and filing of a false tax return, the elements include:

    1. Defendant aided or assisted in, procured, counseled, or advised the preparation or presentation of a document in connection with a matter arising under the internal revenue laws;
    2. The document was false as to a material matter;
    3. The act of the defendant was willful

    And finally, the elements of a charge for “making and subscribing a false tax return” are that:

    1. The defendant made and subscribed a return, statement, or other document which was false as to a material matter;
    2. The return, statement, or other document contained a written declaration that it was made under the penalties of perjury;
    3. The defendant did not believe the return, statement, or other document to be true and correct as to every material matter; and
    4. The defendant falsely subscribed to the return, statement, or other document willfully, with the specific intent to violate the law.

    USSG 2T4.1, the “Tax Table” provides that tax losses of $3,425,654, before considering other relevant factors or characteristics, falls under Offense Level 22 because it is higher than $1,500,000 and lower than $3,500,000. Without a prior criminal history (Criminal History Category I), the Sentencing Table in the United States Sentencing Guidelines provides for a sentence range between 41 and 51 months for Offense Level 22.

     All persons who are merely charged with crimes are presumed innocent until proven guilty. Furthermore, sentences can vary depending on several factors which vary from person to person. This blog post does not implicitly or explicitly suggest there is basis to the prosecuting agency’s allegations or take any position on the strengths or weaknesses of the government’s positions.

    Posted on February 5, 2020 by Benjamin Tu.

    The post Nevada Return Preparer Sentenced to More Than Three Years in Prison for Tax Crimes appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


    Fighting the IRS’s Intentional Disregard of Form W-2 Filing Requirements Penalty Under Section 6721 of the Federal Tax Code

    Can an employer avoid the IRS’s proposed imposition of the penalty for “intentional disregrard” of the Form W-2 filing requirements? Yes, depending on the circumstances. The […] The post Fighting the IRS’s Intentional Disregard of Form W-2 Filing Requirements Penalty Under Section 6721 of the Federal Tax Code appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

    Can an employer avoid the IRS’s proposed imposition of the penalty for “intentional disregrard” of the Form W-2 filing requirements? Yes, depending on the circumstances. The employer may need to show that it did not act voluntarily, that there was reasonable cause for the failure, or that there are significant mitigating factors.

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    The section of the federal tax code which pertains to the failure to file Forms W-2 with “intentional disregard” is 26 U.S.C. Section 7621(e). As provided in that section:

    If 1 or more failures… are due to intentional disregard of the filing requirement (or the correct information reporting requirement), then, with respect to each such failure… the penalty imposed under subsection (a) shall be $500, or, if greater… 10 percent of the aggregate amount of the items required to be reported correctly… .

    Intentional Disregard

    Courts applying 26 U.S.C. § 6721 and its regulations have held that “intentional disregard” means that a party acted “voluntarily in withholding required information, rather than accidentally or unconsciously.” See Purser Truck Sales, Inc. v. U.S., 710 F.Supp.2d 1334, 102 A.F.T.R.2d 2008 (M.D. Ga., 2008); John C. Hom & Assoc. Inc. v. Commissioner, T.C. Summary Opinion 2015-49. “When a taxpayer makes a good faith effort to comply with tax regulations, intentional disregard penalties are less likely to be upheld.” United States v. Quality Medical Consultants, Inc., 214 B.R. 246, 249 (M.D.Fla.1997); Purser Truck Sales, Inc. v. U.S., 710 F.Supp.2d 1334, 102 A.F.T.R.2d 2008 (M.D. Ga., 2008).

    Under this standard, courts refused to sustain the “intentional disregard” penalty in the following scenarios:

    1.         Where the Forms W-2 and W-3 were prepared but placed on a messy desk and accidentally not filed.  American Vending Group, Inc. v. United States, 103 A.F.T.R.2d (RIA) 2009-2181(D. Md. 2009).

    2.         Where an officer testified that he had mailed the Forms W-2 and W-3 and that if they had not been received by the Service, it was not because of intentional disregard on his part. In re Flanary & Sons Trucking, Inc., 93 A.F.T.R.2d (RIA) 2004-1078 (Bankr. E.D. Tenn. 2004).

    3.         Where an accounting employee who was responsible for preparing and filing the information returns made a mistake based on inexperience.  United States v. Quality Medical Consultants, Inc., 214 B.R. 246, 249 (M.D.Fla.1997).

    4.         Where a company, having been assessed a prior penalty for failing to file an information return, south to implement a system to spark the filing of the information returns, but the system did not work.  Tysinger Motor Co., Inc. v. United States, 428 F.Supp.2d 480, 484-85 (E.D.Va.2006).

    Per the IRS’s internal guidelines in Internal Revenue Manual (“IRM”) 20.1.7.8.2 (10-12-2017), “[i]ntentional disregard occurs when a filer who knows, or should know of a rule or regulation, chooses to ignore its requirements.”  IRM 20.1.7.8.2 provides that the facts should show the filer was required to file, knew or should have known of the requirement to file, and consciously chose not to file or recklessly disregarded (i.e., ignored) the duty to file a timely and correct information return.

    Reasonable Cause for Abatement of Penalty

    IRM 20.1.7.12 provides that “an information reporting penalty under IRC 6721, IRC 6722, or IRC 6723 may be waived if it can be shown that the error was due to reasonable cause and not due to willful neglect.”  IRM 20.1.7.12.1(7) provides that reasonable cause for the information return penalties generally exists when the filer acted in a responsible manner, there are significant mitigating factors, or the failure was the result of circumstances beyond the filer’s control. As Section 3.c. of of IRM 20.1.1.3.2 states, “[p]enalty relief may be warranted based on an ‘other acceptable explanation,’ provided the taxpayer exercised ordinary business care and prudence but was nevertheless unable to comply within the prescribed time”.

    Reasonable cause due to reliance on a tax professional is a dispositive defense to a penalty.  See, e.g., Jorgl Ma-Tran Corp. v. Commissioner, 70-T. C. 158, 173 (1978); Pessin v. Commissioner, 59 T.C. 473, 489 (1972); Garcia v. Commissioner, T.C. Memo. 1998-203, affd. without published opinion 190 F.3d 538 (5th Cir. 1999). IRM 20.1.7.12.1(17) provides that the actions of an agent, such as a third party payroll provider contracted to make the filings, can establish that the failure to file was beyond the taxpayer’s control.

    Mitigating Factors

    Section 20.1.7.12 of the IRM has an extensive list of factors the IRS can consider in determining whether the penalty should be applied or abated. Although not usually part of a reasonably cause defense, per se, the IRS will often consider the filer’s compliance history in making a discretionary abatement of a penalty. Per IRM 20.1.7.12.1 (12), the lack of a prior requirement to file a particular form by a first-time filer is generally considered to be a “significant mitigating factor.”  In addition, this section of the IRM provides that a good compliance history with the IRS should be considered.

    Conclusion

    The IRS can get this penalty wrong outright or can fail to account for factors which can be favorable to the taxpayer. When the IRS is investigating Form W-2 compliance, they could erroneously presume that a failure to file is willful without strong enough evidence to support their position and without complete mitigating information from the business. A best practice is to always keep good records of Form W-2 filings and be ready to fight back.

    Posted on 1/26/2020 by Daniel Layton.

    Daniel Layton is a tax attorney serving private clients in Newport Beach, California. He is a former IRS trial attorney and former federal prosecutor in the Tax Division of the Los Angeles U.S. Attorney’s officer.

    The post Fighting the IRS’s Intentional Disregard of Form W-2 Filing Requirements Penalty Under Section 6721 of the Federal Tax Code appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


    The Dual Liability Provisions for a Responsible Person under California Sales Tax Law

    Can you be held responsible by the CDTFA for the unpaid sales tax of your employer’s company or of the company you own? A person may […] The post The Dual Liability Provisions for a Responsible Person under California Sales Tax Law appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel...

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    Can you be held responsible by the CDTFA for the unpaid sales tax of your employer’s company or of the company you own?

    A person may be held personally liable for a business’ unpaid sales tax if the elements of California Revenue & Taxation Code (RTC) § 6829 and Regulation § 1702 are met. Section 6829 requires that the person subject to dual responsibility for the taxes is both a “responsible person” and “willful” as to the nonpayment of taxes. The California Department of Tax & Fee Administration (CDTFA) will conduct an investigation to determine if an individual should be liable under these rules.

    Only a Responsible Person May Be Dually-Liable

    Under Reg. § 1702.5, responsible person liability “applies when the sales taxes are not paid upon termination, dissolution, or abandonment of the corporate business and contains two requirements: the taxpayer must be (1) a responsible person who (2) willfully fails to pay the taxes to the government.” In re Latin, BAP No. EC-08-1082-JuMkH (B.A.P. 9th Cir. 2/11/2009).  “A responsible person may be an officer, but also may be a ‘member, manager, employee, director, shareholder, or other person having control or supervision of, or who is charged with the responsibility for, the filing of returns or the payment of tax or who has a duty to act for the corporation … in complying with any provision of the Sales and Use Tax Law….’” In re Latin. citing Reg. § 1702.5(b)(1). 

    “[T]he touchstone for being a responsible person under Reg. § 1702.5 is whether the individual being assessed possessed a sufficient degree of authority over corporate decision-making to make him a responsible person.” In re Latin, supra at p. 17.  Essentially, this regulation only applies when two requirements are met: the taxpayer must be (1) a responsible person who (2) willfully fails to pay the taxes to the government. In re Latin, supra at p. 16.

    Responsible person liability under Reg. § 1702.6, “imposes personal liability for sales taxes on (1) a corporate officer with control over operations or management of a closely held corporation during a time that the corporation is suspended, or (2) any responsible person who fails to pay or cause to be paid any taxes due from a closely held corporation during a time in which the corporation was suspended.”  In re Latin, supra at pp. 15-16. “The term ‘control over operations or management’ means ‘the power to manage or affect day to day operations of the business’” and there is a rebuttable presumption that an officer has such power.  In re Latin, supra at p. 16, citing Reg. § 1702.6(b)(3).

    Only a Willful Person May Be Liable

    “The willfulness requirement for imposing liability under section 6829 is satisfied where the failure to pay or to cause to be paid the taxes due was the result of an intentional, conscious, and voluntary course or action… .  A person is regarded as having willfully failed to pay taxes or to cause them to be paid where he or she had knowledge that the taxes were not being paid and had the authority to pay the taxes or to cause them to be paid, but failed to do so.” In the Matter of the Administrative Protest Under the Sales and Use Tax Law of Gordon W. Kelley, Appeals Division Board Hearing Summary Case ID 475764 (Cal. BOE Rev. 1:10/5/12).

    Federal courts interpreting these terms have come to the same conclusion.  “Under Reg. § 1702.5(b)(2), willful means ‘voluntary, conscious and intentional.’” In re Latin, supra at p. 17.”  For the taxpayer to be willful, he would have to actually know of the tax delinquencies or act in reckless disregard of those responsibilities.  See Wright v. United States, 809 F.2d 425 (7th Cir. 1987).

    Responsible Person Questionnaire

    When conducting its investigation to determine whether an employee or owner is a responsible person for purposes of applying dual-liability for the unpaid taxes, the CDTFA will first look to internal records (such as return filings) and public records (such as those on file with the Secretary of State) to see who are potentially responsible persons. Once those individuals are identified, they will reach out to them directly and ask for information orally, for documents such as bank statements and cancelled checks, and for completion of a Responsible Person Questionnaire. Click here for a PDF copy of a blank CDTFA Responsible Person Questionnaire.

    The author of this blog post is Daniel Layton, a former IRS trial attorney and ex-federal prosecutor in Los Angeles’s U.S. Attorney’s Office, Tax Division. He is the founder of a tax law practice in Newport Beach, California, where he serves private clients.

    Posted on 12/12/2019 by Daniel Layton.

    The post The Dual Liability Provisions for a Responsible Person under California Sales Tax Law appeared first on Tax Attorney Newport Beach and Fullerton, Orange County, CA | Daniel Layton.


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