Publications

As tax professionals, we have authored or co-authored tax articles on a variety of topics. Below is a list of tax articles we've written. Click the title of the article to read it.

  • State Bar of California, Income and Other Taxes Section: IRS Enforcement Beyond the Offshore Voluntary Disclosure Initiative including a discussion of international discovery methods available to the IRS.  June, 2011

  • Hastings College of the Law, California: Panel discussion on careers in tax controversy.  October 12, 2011

  • Sacramento County Bar Association, Taxation Section: International Discovery and Enforcement Techniques: Betty Williams will describe how the IRS's next wave of investigations of foreign financial institutions, intermediaries, and taxpayers will use new laws (FATCA), increased international information exchange agreements, and administrative and judicial discovery processes in the agency's attempts to identify unreported offshore assets.  October 31, 2011

  • Morning Star Company v. State Board of Equalization, 38 Cal. 4th 324 (Calif. Supreme Court, 2006) (co-counsel): This case raised Constitutional questions regarding the application of a toxic waste tax to entities located in California and the government's illegal application of an "underground" regulation to levy the tax.  The California Supreme Court avoided the Constitutional issues but overturned the government's actions by determining that the government illegally applied an "underground" regulation.

  • New Dynamics Foundation v. United States, Docket No. 99-197T (U.S. Court of Federal Claims, 2006): This case involved declaratory relief challenging the Internal Revenue Service's refusal to grant non-profit status to the plaintiff.  While the court ultimately denied relief to the plaintiff, the court made important findings and conclusions relating to the court's authority to address these types of declaratory relief actions.  In particular, the court determined that the proper standard of review for such cases was de novo.  The court further determined that it was not fettered by the Internal Revenue Service's position that, when an organization modifies its practices at the request of the Internal Revenue Service, the court may choose any date along the continuum from the date of application to the date of the determination letter to determine whether an organization is a qualified non-profit entity.

  • Lecturer: "Tax Issues in Bankruptcy" sponsored by the Bankruptcy and Commercial Law Section of the Sacramento County Bar Association

  • Panel Chair: "Litigating Due Process Claims in the Tax Court" sponsored by the American Bar Association, Section on Taxation, Mid Year Meeting, San Diego, California

  • Lecturer: "Settling Tax Controversies at Appeals (and Beyond ....)" sponsored by the Sacramento Chapter of the California Society of Certified Public Accountants, Taxation Section

  • Lecturer: "Recent Changes in the IRS Approach to Audits and Collections" sponsored by the San Joaquin Chapter of the California Society of Certified Public Accountants, Taxation Section

  • Lecturer: "Current Developments on Individual Tax Planning" sponsored by the
    Association of Government Accountants

  • Lecturer: "The New IRS Allowable Expense Standards for Offers in Compromise and Installment Agreements" sponsored by the Taxation Section of the Sacramento County Bar Association

  • Lecturer: "Preparation of a Tax Court Petition" sponsored by the Young Tax Lawyers Committee of the Taxation Section of the Sacramento County Bar Association

  • Lecturer: "New Developments in Payroll Tax Enforcement and the Trust Fund Recovery Penalty" sponsored by the Sacramento Chapter of the California Society of Certified Public Accountants, Taxation Section

  • Lecturer: "The 1993 Tax Reform Act" sponsored by the American Society of Women Accountants

  • Panel Member: "Update on the Taxation of Wineries," 1993 Wine Industry Conference sponsored by the California Society of Certified Public Accountants

  • Panel Member: "Tax Aspects of Bankruptcy Cases" co-sponsored by the Taxation Section of the Sacramento County Bar Association and the Tax Litigation and Procedure Committee of the Taxation Section of the State Bar of California

  • Lecturer: "Tax Aspects of One Asset Bankruptcy Cases" presented to the Bankruptcy and Commercial Law Section of the Sacramento County Bar Association