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Joseph Wilson

Joseph Wilson

Former IRS, Former Tax Prosecutor, Ex-FTB Attorney Orange County/Newport Beach
  • Tax Law, Criminal Law, White Collar Crime...
  • California
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Summary

Mr. Wilson is a former Federal Prosecutor, IRS Attorney and FTB Attorney. Mr. Wilson is the managing partner at the Wilson Tax Law Group, which is a law firm serving the Newport Beach and Yorba Linda areas that specializes in civil audits and criminal tax matters, involving federal and state tax authorities. The firm represents taxpayers during civil audits, administrative appeals, all phases of collection, judicial proceedings in all trial and appellate courts. The firm handles a wide variety of matters including international compliance and offshore banking matters. The firm is headed by Mr. Wilson, whose impressive background includes positions as federal prosecutor of tax crimes, IRS attorney and Franchise Tax Board attorney. Mr. Wilson handles tax audits, collection, appeals, litigation, FBAR penalty, and criminal tax defense. Mr. Wilson has a particular expertise in handing civil tax audits, civil tax litigation and criminal tax matters, including tax evasion, tax return preparer fraud, white collar crime and asset forfeiture. His experience is extensive representing individuals, businesses, corporations and S-corporations, partnerships, estates, owners, return preparers, and beneficiaries in matters involving income tax audits, FBAR and offshore voluntary disclosure, tax collection, tax litigation, civil injunctions, estate and gift tax, sales tax, payroll tax and property tax. Mr. Wilson actively represents clients in a broad range of international tax matters, including voluntary disclosures, foreign trusts, international compliance, international businesses, and foreign partnerships. Mr. Wilson brings to the firm extensive experience with private and government entities, which greatly benefits the clients.

Practice Areas
  • Tax Law
  • Criminal Law
  • White Collar Crime
  • Gov & Administrative Law
  • Appeals & Appellate
  • Bankruptcy
  • International Law
Additional Practice Areas
  • Criminal Tax Defense
  • International Tax Law
  • Offshore Disclosures
  • IRS Audits
  • FTB Audits
  • Tax Controversy
  • Employment Tax
  • Property Tax
Fees
  • Credit Cards Accepted
  • Rates, Retainers and Additional Information
    Fees are determined based on the case matter and going rate at the time of service
Jurisdictions Admitted to Practice
California
9th Circuit
D.C. Circuit
Federal Circuit
US District Court, Central District CA
US Tax Court
Languages
  • English: Spoken, Written
Professional Experience
Managing Partner
Wilson Tax Law Group, Newport Beach, California
- Current
Mr. Wilson is the founder and managing partner at the Wilson Tax Law Group located in Orange County, California. He has numerous years of handling tax controversy matters. He is a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board. He has litigated a wide variety of civil and criminal tax cases in the United States Court of Appeals for the Ninth Circuit, Federal district court, U.S. Tax Court, California Superior Court, California Board of Equalization, California Unemployment Insurance Appeals Board and Property Tax Assessment Appeals Boards, in matters arising from various types of tax assessments, collection matters and criminal tax investigations.
Tax Attorney
Boutique Tax Controversy Law Firm
-
Worked at a law firm that specializes in civil tax controversy and provides advice regarding tax-related issues in bankruptcy.
Tax Counsel III Specialist
California Franchise Tax Board, Legal Division, Sacramento, California
-
Acted as lead technical counsel in numerous areas of tax law, focusing on abusive tax shelters as well as penalties imposed in connection with tax avoidance transactions at both the participant and promoter level and other subject matter areas. Acted as hearing officer, representing the Franchise Tax Board in protest hearings. Reviewed imposed legislation and suggested amendments to existing law as appropriate. Proposed, drafted, and/or reviewed regulations for submission to the Office of Administrative Law. Assisted the Attorney General and acted as Department liaison in litigation cases on complex tax issues. Prepared and argued complex income and franchise tax cases in administrative appeal hearings before the State Board of Equalization. Acted as lead technical counsel reviewing the work of other attorneys. Reviewed and researched in connection with preparation of rulings and/or position papers on a wide variety of the most difficult questions involving abusive tax shelter and tax avoidance transactions.
Assistant United States Attorney
United States Attorney's Office, Central District of California, Tax Division, Los Angeles, California
-
Represented the United States of America in virtually all types of tax litigation in United States District Court, Bankruptcy Court, Bankruptcy Appellate Panel, Ninth Circuit Court of Appeals and Superior Court, including tax refund suits to determine various types of tax liabilities; the economic substantive of employee stock ownership plans and various sham transactions; wrongful levy actions; suits to enjoin tax collection; actions brought under 28 U.S.C. § 2410(a); suits against IRS employees; affirmative suits to enforce IRS summonses; suits to set aside fraudulent conveyances; actions to reduce tax liabilities to judgment and foreclose federal tax liens; suits to enjoin bogus return preparers; objections to creditor claims in bankruptcy; hearings regarding confirmation of proposed Chapters 11 and 13 plans; motions to sell property free and clear of tax liens; motions to convert or dismiss Chapter 11 cases; motions to lift the automatic stay; grand jury investigations and criminal prosecutions for violations of federal tax laws. Supervised covert investigations, using searches, surveillance, stings, grand jury subpoenas, and other investigatory tools with respect to criminal tax cases.
General Attorney
Internal Revenue Service, Office of Chief Counsel, San Diego, California
-
Represented the Internal Revenue Service in civil tax litigation matters before the United States Tax Court. Supervised and provided legal guidance to the IRS Exam Division on the correct interpretation of tax laws, approval of offers and compromise, and assertion of the civil fraud penalty against certain high profile corporations. Rendered advice to the IRS Collection Division on issues such as lien attachment, lien priority, levies, summonses, redemption, applications for certificates of discharge, and lien releases. Assisted U.S. Department of Justice and the US Attorney’s Office in defense of suits with tax implications brought against the United States. Recommended criminal tax prosecutions to the Department of Justice on behalf of the Internal Revenue Service.
Tax Associate
Deloitte & Touche, San Diego, California
-
Extensive transactional experience in state and local taxes, real estate law, assessment, property tax reductions, complex property, valuations, mergers and acquisitions, international taxation, Sarbanes-Oxley Act of 2002, employment and contract law. Assisted to codify California Assembly Bill 964 into Revenue & Taxation Code §§ 401.17, 441 and 1153.5, dealing with tax assessment and audit methodology for certified aircraft.
Education
University of San Diego
LL.M. / Masters in Law Taxation (2003)
-
James E. Rogers College of Law, University of Arizona
J.D. / Law (2002)
-
Providence College
B.S. / Business (1999)
-
Awards
Top 100 Lawyer
American Society of Legal Advocates
Finance Monthly Global Awards 2017 Winner
Finance Monthly
Who’s Who in Tax Law
Orange County Lawyer Magazine
Top 20 Boutique Firms in California
Daily Journal
OC’s Top Lawyers
OC Register
Wilely W. Manual Pro Bono Services
State Bar of California
Contribution of Pro Bono Services to San Diego residents
Oustanding Service
Legal Aid Society of San Diego
Contribution to Legal Aid Society's Law Income Tax Clinic
Domino
Deloitte & Touche
Leadership and advanced team planning and management
Applaud
Deloitte & Touche
Assisted in a $26 million dollar reduction from the State Board of Equalization that generated over $550,000 in tax savings for a new client
Wilely W. Manual Pro Bono Services
State Bar of California
Contribution of pro bono services to San Diego residents
Outstanding Service
Legal Aid Society of San Diego
Contribution to Legal Aid Society's Low Income Tax Clinic
Applause
Deloitte & Touche
Outstanding leadership and client development
AMJUR
Univesity of San Diego
Tax Valuation, Judge David Laro, US Tax Court
Professional Associations
American Bar Association, Tax Section
Member
Current
Association of Tax Counsel
Member
Current
State Bar of California, Tax Section
Member
Current
San Diego County Bar, Tax Section
Member
Current
Orange County Bar, Tax Section
Member
Current
Orange County Bar Association
Vice Chair
Current
San Diego County Bar Association
Chair
Current
State Bar of California Tax Section
Vice Chair
Current
Young Tax Lawers, San Diego Chapter, State of California
Chair
Current
Publications
Articles & Publications
IRS recommendations in actions relating to Tax Court Decisions
California Network Newsletter
Update on the FBARs
California Network Newsletter
California Tax Network Newsletter
Tax-Exempt Mortgage Bonds: A Way to Alleviate the Self-Inflicted Damage Caused by CALHFA’s Reading of IRC Sec. 143, 2013
State Bar of California, Sacramento Delegation
The Franchise Tax Board Gets More “Firm” About Collecting Delinquent Taxes
California Tax Lawyer
California Tax Network Newsletter
Senate Bill 86 Financial Institution Records Match
Los Angeles & San Francisco Daily Journals
Proposed Revision to Administrative Procedure for Collection Due Process Hearings Pursuant to IRC Section 6330
State Bar of California, Washington DC Delegation
Lack of Statutory Levy Restrictions on Retirement Accounts
State Bar of California, Washington DC Delegation, Tax Notes Today 2011 TNT 111-39
Speaking Engagements
The Household Employment: Are Your Clients Tax Compliant?, The State Bar of California 2017 Section Convention, Sheraton San Diego Hotel & Marina, San Diego
The State Bar of California
Tax Issues Facing the (...GROWING...) Marijuana Industry, 4th Annual Young Tax Lawyers Conference, Golden Gate University School of Law
The State Bar of California Taxation Law Section
Legal Answers
2 Questions Answered

Q. where do I find USTC case "Hancock (T. C. Memo 2012-31) ?
A: The full opinion is here: www.ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=9931. You can just click this link if you don't feel like searching for it on the Tax Court website.
Q. I received a Schedule C letter from the IRS. I don't know why? Please help!!!
A: Letters from the IRS are the start of a conversation and it is your turn to respond politely. They are asking about some items reported on your tax return. So the first step is to review the letter and indentify which tax year is being examined. Then review your tax return and compare it with the issues identified in the IRS letter. It appears they are asking about expenses and maybe income reported on Schedule C. If you didn't have a business you wouldn't normally have a schedule C. Sometimes a return preparer will include a Schedule C for various reasons, e.g., to attempt to qualify for an EIT credit. There is also a great deal of identity theft going around. Fraudsters use other people's SSNs to file tax returns, claiming false tax refunds, which they direct to themselves. If your tax return doesn't have a Schedule C or the items listed in the IRS letter send a letter to the IRS at the address in the audit notice with a copy of your tax return, letting them know the issues in the IRS notice do not match the return you filed. It would also be a good idea to contact a CPA, enrolled agent or tax attorney. You should provide them a copy of the IRS notice and your tax return to verify the issues to determine the best approach.
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Contact & Map
Wilson Tax Law Group - Newport Beach Office
1401 Dove Street
Suite 630
Newport Beach, CA 92660
USA
Telephone: (949) 397-2292
Fax: (714) 694-5998
Wilson Tax Law Group - Yorba Linda Office opening September 2017
18281 Lemon Drive
Yorba Linda , CA 92886
USA
Wilson Tax Law Group - Yorba Linda Office
18032 Lemon Drive
Suite C609
Yorba Linda, CA 92886
USA
Telephone: (714) 463-4430
Fax: (714) 694-5998