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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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    Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government

    In tax cases, the IRS and Department of Justice will generally prosecute cases under Title 26, the Internal Revenue Code. However, if a false statement is […] The post Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

    In tax cases, the IRS and Department of Justice will generally prosecute cases under Title 26, the Internal Revenue Code. However, if a false statement is made outside of a tax document, they may utilize title 18. Section 1001 of Title 18 of the United States Code criminalizes willful false statements or concealment, providing:

    (a)Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully—

    (1)falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

    (2)makes any materially false, fictitious, or fraudulent statement or representation; or

    (3)makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;shall be fined under this title, imprisoned not more than 5 years or, if the offense involves international or domestic terrorism (as defined in section 2331), imprisoned not more than 8 years, or both. If the matter relates to an offense under chapter 109A, 109B, 110, or 117, or section 1591, then the term of imprisonment imposed under this section shall be not more than 8 years.

    One of the reasons prosecutors often prefer Title 26 criminal statutes is that the limitations period for prosecution is six years. The statute of limitations for bringing charges under 18 U.S.C. Section 1001 is set by 18 U.S.C. Section 3263 at only five years. “The statute of limitations begins to run when the crime is complete.” United States v. Smith, 740 F.2d 734, 736 (9th Cir. 1984). Under 18 U.S.C. § 1001, the crime is complete when the false statement is submitted or mailed to an agent or agency of the federal government, regardless of whether it is received or relied upon. Id.; United States v. Heacock, 31 F.3d 249, 257 n. 13 (5th Cir. 1994). This is the pertinent moment the limitations period commences due to the statute’s use of the words “in any matter within the jurisdiction of the executive, legislative, or judicial branch of the government,” as it does not fall into the jurisdiction of the federal government until it is submitted to a federal agency. See United States v. Lutz, 154 F.3d 581, 586-87 (6th Cir. 1998).

    Notably, the statute of limitations can be waived by agreement. The court in United States v. Caldwell, relying on its holding in United States v. Akmakjian, held that the statute of limitations is waivable by agreement. Caldwell, 859 F.2d 805, 806 (9th Cir. 1988); Akmakjian, 647 F.2d 12, 14 (9th Cir.1981) ( holding that the Statute of limitations was not jurisdictional and was waivable by a defendant). The proper standard by which to judge the validity of waivers is whether they are entered into knowingly and voluntarily. Caldwell, 859 F.2d at 809 (citing United States v. Wild, 551 F.2d 418 (D.C. Cir. 1977)). Applying this standard, courts suggest that when an express agreement was entered into for the benefit of the defendant (for example, in hopes that further inquiry will lead to no indictment at all) with good faith on the part of the government, the defendant is unable to argue that the agreement was not knowingly or voluntarily entered into, even if the prosecution used that time to strengthen its case. United States v. Del Percio, 224 F.3d 847, 859 (6th Cir. 2000); Caldwell, 859 F.2d at 809; Wild, 551 F.2d at 423.

    Further, several circuits hold that an agreement to waive the statute of limitations is to be interpreted by applying the same principles applicable to other contracts. See United States v. Spector, 55 F.3d 22, 25-26 (1st Cir. 1995)(applying the principles of estoppel); United States v. Richards, 925 F. Supp. 1097, 1101-02 (N.J. Dist. 1996). The sixth circuit has held, in addition, that the waiver must expressly waive the statute of limitations, not implied as a necessary part of another agreement. See United States v. Crossley, 224 F.3d 847, 859 (6th Cir. 2000) (following Benes v. United States, 276 F.2d 99, 108-09 (6th Cir. 1960). But see United States v. Doyle, 348 F.2d 715 (2nd Cir. 1965) (a plea of guilty implicitly waives a statute of limitations defense for that crime).

    Posted on: 04/16/2019

    By: Daniel W. Layton

    Daniel W. Layton is a former federal prosecutor who worked on criminal tax matters and civil tax matters while at the U.S. Attorney’s Office in downtown Los Angeles. He has his own practice in Orange County, CA.

    The post Statute of Limitations for 18 U.S.C. Section 1001, False Statements to the U.S. Government appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


    Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute

    What is the Federal Insolvency Statute? Where the delinquent taxpayer is insolvent but has not filed a petition in bankruptcy, the IRS’ prior right to payment […] The post Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

    What is the Federal Insolvency Statute?

    Where the delinquent taxpayer is insolvent but has not filed a petition in bankruptcy, the IRS’ prior right to payment is established by the Federal Insolvency Statute, 31 U.S.C. § 3713(a). That statute states, in relevant part:

    (a)(1) A claim of the United States Government shall be paid first when –
    (A) a person is indebted to the Government and is insolvent and –
    (i) the debtor without enough property to pay all debts makes a voluntary assignment of property;
    (ii) property of the debtor, if absent, is attached; or
    (iii) an act of bankruptcy is committed; * * *

    The statute is rooted in English common law and embodies the philosophy that “The king’s debtor is dying, the king shall first be paid.” Magna Carta, 1225, 9 Hen. 3, c. 18; See also United States v. Moore, 423 U.S. 77, 81-82, 96 S. Ct. 310, 313 (1975); United States v. State Bank of North Carolina, U.S. 29 (1932). The statute is liberally construed to effect the purpose of securing adequate revenue to the United States Treasury. Moore, 423 U.S. at 86.

    Can an Executor, Conservator, or Trustee of a Trust or Estate that owes taxes be personally liable?

    In certain circumstances, yes. Under subsection (b) the federal insolvency statute, “A representative of a person or an estate (except a trustee acting under title 11) paying any part of a debt of the person or estate before paying a claim of the Government is liable to the extent of the payment for unpaid claims of the Government.” 31 U.S.C. § 3713(b). Thus, an executor, conservator, or trustee whose estate or trust is insolvent and who, after an “act of bankruptcy,” does not pay a priority claim of the IRS first, will be personally liable. The Federal Insolvency Statute is applicable in tax cases. It is well settled that taxes are claims of the United States. See, e.g., Price v. United States, 269 U.S. 492, 46 S. Ct. 180 (1926) (applying predecessor to section 3713, stating that “the claim for taxes is paramount to all other claims against the citizen”).

    Also, an estate or trust is insolvent as required by part (a)(1)(A) when it owes more than it has in assets. “Insolvent” has long been understood to mean insolvent in the bankruptcy sense, which is when the debtor does not have enough property to pay all debts. United States v. Oklahoma, 261 U.S. 253, 260-61 (1923) (applying predecessor to section 3713); United States v. Key, 397 U.S. 322, 328 n. 7 90 S. Ct. 1049, 1053 n. 7 (1970) (same). See also Lakeshore Apartments, Inc.v. United States, 351 F.2d 349, 353 (9th Cir. 1965). When the total of the tax debt plus other debts exceeds the property of a trust or estate, it is insolvent.

    Placing assets in the control of the probate court, in a conservatorship, over an estate and distributing assets to the conservatee and to creditors satisfies the “act of bankruptcy” requirement under subpart (iii). See United States v. New York Ins. Dep’t., 657 F. Supp. 27, 29 n.2 (S.D.N.Y. 1986) (finding that government would also be entitled to priority under section 3713 on claim to money held in conservatorship); In re Taxable Municipal Bond Securities Litigation, 1991 WL 197 164 *5, 1991 U.S. Dist. LEXIS 13449 *16 (E.D. La. 1991) (“A predominant function of the conservatorship proceeding is to prioritize claims… .”); United States v. Oxner, 229 F.Supp. 58, 60 (E.D. Ark. 1964) (predecessor statute to 31 U.S.C. 3713 applied to state court guardianship proceedings, and therefore, guardian who made payment to her ward did so at her peril and became personally liable for United States’ claim); Conservatorship of Hume v. Hume, 139 Cal . App. 4th 393, 400 (2006) (traditionally, state courts subject local assets to their probate administration to protect local creditors); Lakeshore Apts., Inc., 351 F.2d at 353 (acts of bankruptcy includes giving preference to creditors).

    But, the IRS is not always first. Under 26 U.S.C. § 6323(a), the exception to the Federal insolvency statute exists when a judgment creditor has a perfected lien recorded before the Federal tax lien is recorded.

    When a trustee, conservator, or executor of an estate is concerned with their own liability due to potential decisions to pay those other than the IRS, an interpleader action is often considered. Interpleader actions are authorized by 28 U.S.C. § 1335 and Rule 22 of the Federal Rules of Civil Procedure where persons holding funds to property upon which conflicting claims are being made by others may deposit the funds with the District Court and require the other parties to litigate their interests.  Libby v. City Nat’l Bank, 592 F.2d 504, 507 (1978). Because the risk of handling these issues wrong can be high, it is important to consult with or retain experienced counsel.

    Posted on 3/12/2019 by Daniel W. Layton. Mr. Layton is a tax attorney with offices in Newport Beach and Manhattan Beach, California, whose experience includes the IRS Office of Chief Counsel and the U.S. Dept. of Justice, U.S. Attorney’s Office, Tax Division.

    The post Trustees and Executors Should Worry When Taxes are Owed: The Federal Insolvency Statute appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


    Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF

    On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 […] The post Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

    On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 (PDF attached here). The court rejected defendants’ argument that the IRS had reversed the penalties. The court found that the assessment against the wife was improper because she did not have financial interest or signature authority.

    The court enforced the willfulness penalty against the husband, basing the willfulness finding almost entirely on the information in schedule B regarding foreign accounts. In addition, the court declined to follow the finding of United States v. Colliot, 2018 WL 2271381 (W.D. Texas 2018) that IRS regulation limits the penalty to $100,000 and instead followed the U.S. Court of Federal Claims Ruling in Kimble v. United States, No. 17-421, 2018 WL 6816546 (Fed. Cl. Dec. 27, 2018) that the regulation was invalid as inconsistent with the statute.

    The post Maryland Federal District Court Issues Willful FBAR Penalty Opinion in United States v. Horowitz – No. PWG-16-1997 – PDF appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


    When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien?

    When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien? Judicial discretion to decline foreclosure in Federal […] The post When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien? appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

    When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien?

    Judicial discretion to decline foreclosure in Federal tax lien cases is available, but very limited, under 26 U.S.C. § 7403. Courts have held it is available to protect a third party interest in the property when a variety of factors weighs in favor of exercising discretion and available when
    the value of the property had declined so that the equity of the property was depleted by lienholder senior to the government.

    The seminal case on this point is U.S. v Rodgers, 461 U.S. 677, 710-11 (1983). Rodgers held that the court could use discretion where necessary to protect the interest of a third party and listed factors to determine whether this limited discretion to not authorize the foreclosure should be used. Id. The Rodgers factors serve “to provide a framework under which it must justify a refusal to order a sale under § 7403.” U.S. v. Davenport, 106 F.3d 1333, 1338 (7th Cir. 1997). Even with respect to third parties, courts need not apply these factors before decreeing a sale under § 7403, consideration of these factors is “a matter of judicial grace.” Id.

    With respect to equitable discretion in favor of taxpayers themselves, the Supreme Court in Rodgers declined to provide them such discretionary protection, stating it could “think of virtually no circumstances… in which it would be permissible to refuse to authorize a sale simply to protect the interests of the delinquent taxpayer himself or herself.” Rodgers, 461 U.S. at 709. This holding is far from dicta, as the Supreme Court declined to engage in an analysis similar to the one it used for determining whether to exercise the limited discretion with respect to a third party where Joerene Ingram (whose similar case was consolidated with Rodgers’) was subject to a joint lien for $283.33, plus interest, as she was not a third party. Id. at 712. The different outcome for a third party versus a delinquent taxpayer is stark, as the Supreme Court indicated that the simple act of Ingram’s payment of the nominal amount of the joint liability would allow it to use the discretionary analysis. Id.

    Since the Supreme Court’s holding, in Rodgers, that the discretion to not authorize foreclosure is limited and to be used sparingly, taxpayers have routinely argued for the Rodgers holding to be used more expansively. See, e.g., Davenport, 106 F.3d 1338, n. 7. However, the Supreme Court Rodgers did not simply fail to consider justice as it may apply to a delinquent taxpayer because, in a footnote, it alluded that other options that do not amount to non-authorization of a foreclosure would suffice, including temporarily postponing a forced sale or making it subject to an upset price. In United States v. Moyer, for example, the District Court for the Northern District of California considered whether to stay its order of foreclosure, which was based on a stipulation by the parties, based upon the taxpayer’s showing that the value of the property had declined so that the equity of the property was depleted by lienholder senior to the government. United States v. Moyer, No. 07-00510, 2008 WL 3478063, 102 A.F.T.R. 2d RIA 5748 (N.D. Cal. Aug. 12, 2008).

    The Moyer case relied on the holding in U.S. v. Boyd, 426 F.2d 477, 481 (5th Cir. 1957), that a decree of foreclosure would not be appropriate if senior lienholders exhaust the equity. While it is important to note that Boyd is a pre-Rodgers case (Rodgers, on certiorari from two consolidated cases, overruled the 5th circuit’s more extensive use of discretion), and its holding would be limited to the extent it went beyond the limits of Rodgers, the Moyer case is easily reconciled with Rodgers. In the Moyer case, the district court merely stayed its order to foreclose, which is an acceptable exercise to protect the interest of the taxpayer per note 39 in Rodgers. Id.

    Daniel W. Layton, the author of this post, is a former IRS trial attorney and former Federal prosecutor who was tasked with handling criminal tax prosecutions and civil litigation including tax refund suits, lien enforcement and foreclosures. As a tax attorney in private practice in Newport Beach, he uses his knowledge of IRS procedures and rules to keep the IRS in check and protect his clients’ rights. He may be contacted at (949) 801-9829.

    The post When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to a Federal Tax Lien? appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


    Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens

    Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens California’s Homestead exemption is found in Chapter 4 of Division […] The post Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

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    Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens

    California’s Homestead exemption is found in Chapter 4 of Division two of the California Code of Civil Procedure, pertaining to Enforcement of Money Judgments, in sections 704.710 – 704.850. These sections protect up to $175,000 of a residence in certain circumstances, including if one of the spouses is over 65, and as little as $75,000 if the resident is a single person living alone. The Homestead exemption filed pursuant to CCP § 704.730 is also applicable in Federal bankruptcy by virtue of § 522(b)(3)(A). FN1.

    A Homestead exemption applies, generally, to a principal dwelling of the judgment debtor or the spouse when the lien attached and which is continuously resided in through the court’s Homestead determination. It is initially claimed by filing a complete notarized Homestead declaration in the county recorder’s office where the property sits. A step-by-step guide can be found here.

    Claiming the Homestead Exemption in Bankruptcy Court May Only Be Keeping Your Home’s Equity for Payment of the Federal Tax Lien

    Although the Homestead exemption often is a godsend for homeowners in financial troubles, if you have a Federal IRS Tax Lien against you, it may only be securing the IRS’s interest for later collection of any equity in the home. Bankruptcy discharge only extinguishes in personam modes (against the individual) of enforcing a claim, leaving in rem (against the property) modes in tact. FN2. Tax liens survive bankruptcy, allowing the government to collect against the property of the debtor even when the underlying tax debt is discharged in bankruptcy. FN3. Moreover, where a debtor exempts property from the bankruptcy estate pursuant to 11 U.S.C. 522 and obtains a discharge while retaining that property, the exempted property remains subject to properly filed tax liens. FN4. The Homestead exempted property owned by the taxpayer, retained through the Bankruptcy proceeding, remains subject to the tax liens of the United States

    FN1. https://taxattorneyoc.com/wp-content/uploads/2019/01/In-Re-Pass-BAP-9th-Circuit-Opinion-2016-California-Homestead-Exemption-Bankruptcy.pdf

    FN2. Johnson v. Home State Bank, 501 U.S. 78, 84, 111 S. Ct. 2150, 2154 (1991).

    FN3. In Re Isom v. United States of America, 901 F.2d 744, 746 (9th Cir. 1990).

    FN4. In Re Demarah v. U.S., 62 F.3d 1258 1248, 1252 (9th Cir. 1995) (citing Isom and 11 U.S.C. 522(c)(2)(B)).

    Daniel W. Layton, the author of this post, is a former IRS trial attorney and former Federal prosecutor who was tasked with handling criminal tax prosecutions and civil litigation including tax refund suits, lien enforcement and foreclosures. As a tax attorney in private practice in Newport Beach, he uses his knowledge of IRS procedures and rules to keep the IRS in check and protect his clients’ rights. He may be contacted at (949) 801-9829.

    The post Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


    Does Res Judicata Apply to Stipulated Tax Court Decisions?

    Does Res Judicata Apply to Stipulated U.S. Tax Court Decisions? The judicial principle of res judicata applies to stipulated Tax Court Decisions. However, if the stipulated […] The post Does Res Judicata Apply to Stipulated Tax Court Decisions? appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel...

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    Does Res Judicata Apply to Stipulated U.S. Tax Court Decisions?

    The judicial principle of res judicata applies to stipulated Tax Court Decisions. However, if the stipulated decision is opaque, the doctrine does not include elements of a particular underlying theory that one side or the other believed justified settlement.

    The U.S. Supreme Court found that res judicata applied in tax litigation. Commiss’r v. Sunnen, 333 U.S. 591, 598 (1948). Established primarily to avoid repetitive litigation and thereby conserve judicial resources, the doctrine of res judicata directs that a prior judgment bars a subsequent action (1) between the same parties or their privies (2) when the claims and the facts surrounding the two causes of action are the same and (3) the prior judgment was a final judgment on the merits entered into by a court of competent jurisdiction. Id. at 597. Where the litigation is based upon a different cause of action but with points that were determined by the prior matter the principal is more accurately referred to as collateral estoppel, and the parties may only litigate the points that were not determined by the prior matter. See id. at 598.

    Furthermore, various affirmative equitable defenses including duress, unclean hands, and estoppel, cannot be applied to defeat the res judicata effect of the Tax Court’s judgment. “The doctrine of res judicata serves vital public interests beyond any individual judge’s ad hoc determination of the equities in a particular case. There is simply ‘no principal of law or equity which sanctions the rejection by a federal court of the salutary principle of res judicata.” Federated Dep’t Stores v. Moitie, 452 U.S. 394, 401, 101 S. Ct. 2424, 2529 (1981).

    Moreover, the United States Tax Court has been recognized as a court of competent jurisdiction with respect to the application of res judicata. See Russell v. Commiss’r, 678 F.2d 782 (9th Cir. 1982) (holding that the Tax Court is a court of competent jurisdiction such that the doctrine of res judicata applies to that litigation in Tax Court). Furthermore, United States Tax Court decisions entered pursuant to stipulation constitute final judgments for purposes of res judicata. See U.S. v. Int’l Building Co., 345 U.S. 502, 73 S. Ct. 807 (1953); U.S. v. Shanbaum, 10 F.3d 305, 313 (5th Cir., 1994); Trent v. Commiss’r, T.C. Memo 2002-285; Cf. Ariz. v. Cal., 530 U.S. 392, 120 S. Ct. 2304 (2000) (res judicata attaches to a stipulated judgment but does not include elements of a particular underlying theory where the stipulation is opaque).

    Daniel W. Layton, the author of this post, is a former IRS trial attorney and former Federal prosecutor who was tasked with handling criminal tax prosecutions and civil litigation including tax refund suits, lien enforcement and foreclosures. As a tax attorney in private practice in Newport Beach, he uses his knowledge of IRS procedures and rules to keep the IRS in check and protect his clients’ rights. He may be contacted at (949) 801-9829.

    The post Does Res Judicata Apply to Stipulated Tax Court Decisions? appeared first on Tax Attorney Newport Beach-Manhattan Beach-Fullerton | Daniel Layton.


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