Insights

Tax summaries and published work.

Practical summaries of federal and California tax problems, and published analysis for practitioners.

Featured Analysis

In-depth analysis of consequential tax questions.

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Tax Policy & Legislation · Updated August 1, 2026

All Your Basis Are Belong to You

Why Congress should let taxpayers elect a one-time deemed sale of appreciated property, pay current tax, and establish a fair-market-value basis.

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Tax Collection · Updated July 6, 2026

California’s 20-Year Tax Collection Clock Has a Constitution Problem

A 1932 constitutional amendment presumes every tax paid after 30 years. Whether that protection reaches California income-tax collection remains an open question.

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Tax Planning

Practical tax planning summaries for owners, investors, and individuals making consequential financial decisions before the tax result is locked in.

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Tax Audits

Plain-English summaries of IRS audit timelines, notices, records, and decisions that can change the course of a tax dispute.

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Tax Penalties

Summaries of penalty notices, reasonable cause, administrative waivers, California relief, and the records needed to support an abatement request.

Tax Collection

Analysis of federal and California tax collection periods, liens, limitations, and the procedural questions that can determine whether an old liability remains enforceable.

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Published Work

Articles and practitioner commentary published outside the firm.

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Tax Professionals

Decision overviews for choosing the right tax advisor when compliance, legal risk, privilege, or controversy strategy may change the answer.

Tax Policy & Legislation

Long-form analysis of federal tax policy, proposed legislation, and the structural questions that shape how gain, basis, and tax administration work.

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Civil & Criminal Tax Enforcement

Summaries of civil and criminal tax enforcement, including IRS examinations, fraud penalties, IRS CI referrals, voluntary disclosure, and early warning signs.

Data Analysis

IRS data, trend analysis, and reference material for understanding tax administration and procedure.

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