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Daniel W. Layton

Daniel W. Layton

Former Federal tax prosecutor and former trial attorney for the IRS
  • Tax Law, White Collar Crime, Estate Planning...
  • California
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Summary

Daniel W. Layton is a former Federal tax prosecutor and trial attorney for the IRS. His practice as a tax attorney is dedicated to handling all aspects of tax controversy, including audits, collection, international tax, and criminal tax defense. Mr. Layton has extensive experience and insight from his time in the government sector, which greatly benefits his clients. As a former Federal tax prosecutor with the U.S. Department of Justice, in the Tax Division of the U.S. Attorney’s Office in Los Angeles, and a former IRS trial attorney in San Jose, he has litigated a wide variety of civil and criminal tax cases in Federal district court and in U.S. Tax Court arising from notices of deficiency, collections determinations, and innocent spouse determinations. Mr. Layton’s tax litigation and trial experience in Tax Court, U.S. District Court, and the Ninth Circuit has resulted in at least 30 reported decisions.

Practice Areas
  • Tax Law
  • White Collar Crime
  • Estate Planning
  • Criminal Law
  • International Law
Additional Practice Areas
  • FBAR, Foreign Bank Account Reporting and Offshore Voluntary Disclosure
  • Tax Controversy
Fees
  • Credit Cards Accepted
Jurisdictions Admitted to Practice
California
9th Circuit
United States Court of Federal Claims
United States Tax Court
Languages
  • English
Professional Experience
Partner
Layton & Lopez Tax Attorneys, LLP
- Current
Owner
Tax Attorney OC
- Current
Assistant U.S. Attorney, Tax Division
Department of Justice, United States Attorney's Office, Los Angeles
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As a former Federal prosecutor, Mr. Layton understands how the IRS conducts its investigations against individuals alleged to have committed tax evasion and tax fraud. Mr. Layton’s district court experience includes litigation of claims for refund, collections cases, IRS summons proceedings, injunctions, and criminal tax cases. Mr. Layton has successfully litigated several high profile district court cases, including a tax shelter case with over $350 million at issue and one of the first cases involving disclosure of foreign holders of domestic bank accounts. He has significant experience in the area of identity theft and tax fraud, holding the position of Stolen Identity Refund Fraud coordinator for the U.S. Attorney’s Office.
General Attorney
Internal Revenue Service, Office of Chief Counsel, San Jose, California
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As a trial attorney for the IRS, Mr. Layton tried civil tax cases appealed to the U.S. Tax Court, including fraud and innocent spouse cases. Mr. Layton also provided training to revenue officers and revenue agents in San Jose field offices and in the Fresno Service Center, advised a specialized group of revenue agents assigned to tax shelters, and reviewed the IRS’s proposed assertions of penalties, including Foreign Bank Account (FBAR) penalties for undisclosed offshore accounts and civil fraud penalties.
Education
Golden Gate University School of Law
LL.M. (2006) | Taxation
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The University of Chicago Law School
J.D. (2004) | Law
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Honors: Victor McQuistion Scholar
California State University - San Diego State University
B.A. (2000)
Honors: Cum Laude; With Distinction
Awards
Top 100 Lawyers, Tax Law, California
American Society of Legal Advocates
A Top Tax Attorney
Coast Magazine
Nominee, Attorney General's Award
Department of Justice
5 year Service Recognition
Department of Justice
Bravo!
Internal Revenue Service
Professional Associations
Orange County Bar Association, Tax Section
Chair-Elect
- Current
California Bar Association, Tax Section
Member
- Current
Orange County Bar Association, Tax Section
Secretary/Treasurer
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Orange County Bar Association, Tax Section
Chair
-
Orange County Bar Association, Tax Section
Chair-Elect
-
Orange County Bar Association, Tax Section
Secretary/Treasurer
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Publications
Speaking Engagements
CDTFA One Year Later and the Effects of the Supreme Court’s Wayfair Opinion on California Sales and Use Tax, Tax Law Section Meeting, Newport Beach, CA
Orange County Bar Association, Tax Section
(Co-Presenter)
Recognizing and Ethically Handling Conflicts of Interest in Various Common Tax Representation Scenarios, Newport Beach, California
Orange County Bar Association, Tax Section
Tax Tips for Law Firms
Orange County Bar Association
Social Media
Contact & Map
Daniel W. Layton, Esq.
1451 Quail St., Suite 210
Newport Beach, CA 92660
USA
Telephone: (949) 301-9829
Daniel W. Layton, Esq.
1500 Rosecrans Ave, Suite 500
Manhattan Beach, CA 90266
USA
Telephone: (310) 693-0829
Daniel W. Layton, Esq.
1370 N. Brea Blvd., Suite 140
Fullerton, CA 92835
USA
Telephone: (949) 301-9829