Joseph Wilson

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.

• Criminal Tax Defense
• International Tax Law
• Offshore Disclosures
• IRS Audits
• FTB Audits

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• Rates, Retainers and Additional Information
  Fees are determined based on the case matter and going rate at the time of service

California

Since 2003

9th Circuit

Since 2003

D.C. Circuit

Since 2011

Federal Circuit

Since 2011

US District Court, Central District CA

Since 2008

US Tax Court

Since 2005

Managing Partner

Wilson Tax Law Group, Newport Beach, California

2014 - 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

2011 - 2014

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

2010 - 2011

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

2008 - 2010

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

2006 - 2008

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

2003 - 2006

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.

University of San Diego

LL.M. (2003) | Masters in Law Taxation

2002 - 2003

James E. Rogers College of Law, University of Arizona

J.D. (2002) | Law

1999 - 2002

Providence College

B.S. (1999) | Business

1995 - 1999

Top 100 Lawyer

American Society of Legal Advocates

2017

Finance Monthly Global Awards 2017 Winner

Finance Monthly

2017

Who’s Who in Tax Law

Orange County Lawyer Magazine

2016

Top 20 Boutique Firms in California

Daily Journal

2016

OC’s Top Lawyers

OC Register

2014

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

IRS recommendations in actions relating to Tax Court Decisions

California Network Newsletter

August, 2013

Update on the FBARs

California Network Newsletter

May, 2013

California Tax Network Newsletter

February, 2013

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

February, 2013

The Franchise Tax Board Gets More “Firm” About Collecting Delinquent Taxes

California Tax Lawyer

2012

Employment Taxes, webinar

September 17, 2018

California Lawyers Association

The Household Employment: Are Your Clients Tax Compliant?, The State Bar of California 2017 Section Convention, Sheraton San Diego Hotel & Marina, San Diego

August 18, 2017

The State Bar of California

Tax Issues Facing the (...GROWING...) Marijuana Industry, 4th Annual Young Tax Lawyers Conference, Golden Gate University School of Law

May 22, 2017

The State Bar of California Taxation Law Section

Q. where do I find USTC case "Hancock (T. C. Memo 2012-31) ?

August 13, 2017

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!!!

August 1, 2017

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. ... Read More