PREMIUM
Joseph Wilson

Joseph Wilson

Former IRS, Former Tax Prosecutor, Ex-FTB Attorney Orange County/Newport Beach
  • Tax Law, White Collar Crime, Gov & Administrative Law ...
  • California
Badges
Claimed Lawyer ProfileQ&ALII GoldSocial MediaResponsive Law
Biography

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.

Education
University of San Diego
LL.M. (2003) | Masters in Law Taxation
-
University of San Diego Logo
James E. Rogers College of Law, University of Arizona
J.D. (2002) | Law
-
James E. Rogers College of Law, University of Arizona Logo
Providence College
B.S. (1999) | Business
-
Placeholder image for education.
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.
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
Employment Taxes, webinar
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
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
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
Placeholder image for professional associations.
Association of Tax Counsel
Member
Current
Placeholder image for professional associations.
State Bar of California, Tax Section
Member
Current
Placeholder image for professional associations.
San Diego County Bar, Tax Section
Member
Current
Placeholder image for professional associations.
Orange County Bar, Tax Section
Member
Current
Placeholder image for professional associations.
Orange County Bar Association
Vice Chair
Current
Placeholder image for professional associations.
San Diego County Bar Association
Chair
Current
Placeholder image for professional associations.
State Bar of California Tax Section
Vice Chair
Current
Placeholder image for professional associations.
Young Tax Lawers, San Diego Chapter, State of California
Chair
Current
Placeholder image for professional associations.
Jurisdictions Admitted to Practice
California
Placeholder image for jurisdictions.
9th Circuit
Placeholder image for jurisdictions.
D.C. Circuit
Placeholder image for jurisdictions.
Federal Circuit
Placeholder image for jurisdictions.
US District Court, Central District CA
Placeholder image for jurisdictions.
US Tax Court
Placeholder image for jurisdictions.
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
Practice Areas
    Tax Law
    Business Taxes, Criminal Tax Litigation, Estate Tax Planning, Income Taxes, International Taxes, Payroll Taxes, Property Taxes, Sales Taxes, Tax Appeals, Tax Audits, Tax Planning
    White Collar Crime
    Gov & Administrative Law
    Administrative Law, Election Law, Government Contracts, Government Finance, Legislative & Government Affairs
    Appeals & Appellate
    Civil Appeals, Federal Appeals
    Bankruptcy
    Chapter 11 Bankruptcy, Chapter 13 Bankruptcy, Chapter 7 Bankruptcy, Debt Relief
    International Law
    Human Rights, Imports & Exports
    Criminal Law
    Criminal Appeals, Drug Crimes, Expungement, Fraud, Gun Crimes, Internet Crimes, Sex Crimes, Theft, Violent Crimes
Additional Practice Areas
  • Criminal Tax Defense
  • International Tax Law
  • Offshore Disclosures
  • IRS Audits
  • FTB Audits
  • Tax Controversy
  • Employment Tax
  • Property Tax
Languages
  • English: Spoken, Written
  • Spanish: Spoken
Legal Answers
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.
... Read More
View More Answers
Websites & Blogs
Website
Wilson Tax Law Group
Blog
Newport Beach Tax Attorney Blog
Blog
Contact & Map
Wilson Tax Law Group - Newport Beach Office
Main Office
895 Dove Street
Suite 300
Newport Beach, CA 92660
Telephone: (949) 397-2292
Fax: (949) 535-2234
Monday: 8:30 AM - 6 PM (Today)
Tuesday: 8:30 AM - 6 PM
Wednesday: 8:30 AM - 6 PM
Thursday: 8:30 AM - 6 PM
Friday: 8:30 AM - 6 PM
Saturday: Closed
Sunday: Closed
Notice: Closed on most federal holidays
Wilson Tax Law Group - Yorba Linda Branch Office
18281 Lemon Drive
Yorba Linda , CA 92886
Telephone: (714) 463-4430
Fax: (714) 694-5998
Monday: 8:30 AM - 6 PM (Today)
Tuesday: 8:30 AM - 6 PM
Wednesday: 8:30 AM - 6 PM
Thursday: 8:30 AM - 6 PM
Friday: 8:30 AM - 6 PM
Saturday: Closed
Sunday: Closed
Notice: Closed on most federal holidays.
Wilson Tax Law Group - Mailing Address
18032 Lemon Drive
Suite C609
Yorba Linda, CA 92886
Telephone: (714) 463-4430
Fax: (714) 694-5998
Monday: Open 24 hours (Today)
Tuesday: Open 24 hours
Wednesday: Open 24 hours
Thursday: Open 24 hours
Friday: Open 24 hours
Saturday: Open 24 hours
Sunday: Open 24 hours