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Options are available when a tax controversy arises with the Internal Revenue Service and the California Franchise Tax Board. Outside of bankruptcy, taxpayers may seek penalty relief, request reconsideration of an audit, or file an offer in compromise based on doubt as to liability, or seek innocent spouse relief. Unbeknownst to some, even during bankruptcy, a debtor can bring an adversary proceeding under 11 USC § 505(a) to reduce a potentially large debt based on new evide

In the Eighteenth Century, renowned English justice and commentator on common law, Sir William Blackstone, stated that “[the king’s] debt shall be preferred before a debt to any of his subjects.”[i] Although Sir Blackstone made this pronouncement many years before the existence of the Internal Revenue Service (the “IRS”) or the California Franchise Tax Board, the principle still often applies today. In a recently published article, Steven L. Walker provides trusts and estates

This article provides practical guidance to practitioners with clients who are facing a Federal or State tax lien and are wondering what...