Insights
Insights Archive
Browse every insight, published piece, and court filing by subject.
Tax Planning
Practical tax planning summaries for owners, investors, and individuals making consequential financial decisions before the tax result is locked in.
- Moving Out of California Before a Business Sale: Residency, Timing, and Sourcing
Moving out of California before a business sale, stock sale, or option exercise raises residency and sourcing questions. What the FTB examines, and when to plan.
- Investor, Trader, or Dealer? How Tax Classification Changes Gains, Losses, and Deductions
How the investor, trader, or dealer classification can change gains, losses, deductions, and planning choices.
Tax Audits
Plain-English summaries of IRS audit timelines, notices, records, and decisions that can change the course of a tax dispute.
- IRS Audit Documents: What You Need and Why
The records an IRS audit may request, how to organize support for each item, and what to do when a document is missing.
- What Triggers an IRS Audit?
There is no single IRS audit trigger. Learn how the IRS selects returns for examination, which common red flags are myths, and why documentation matters.
- IRS Audit Reconsideration: When a Tax Lawyer Can Help
Can you reopen a closed IRS audit? Learn when reconsideration may fit, what records matter, and when a tax lawyer can help protect your options.
- IRS Notice of Deficiency: What the 90-Day Letter Means
What an IRS notice of deficiency means, why the 90-day deadline matters, and how to protect your options before the proposed tax becomes assessed.
- How Far Back Can the IRS and California Audit and Collect?
Federal and California audit, assessment, extension, and collection time limits for old tax years.
- IRS Audit Letter: What to Do Before You Respond
A practical first-response guide for verifying an IRS audit letter, understanding the audit type, protecting deadlines, and organizing the right records.
Tax Penalties
Summaries of penalty notices, reasonable cause, administrative waivers, California relief, and the records needed to support an abatement request.
- Reasonable Cause Penalty Relief: IRS and California Penalty Abatement
IRS and California penalty relief, including reasonable cause, administrative waivers, documentation, procedural defenses, and appeal options.
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.
- 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.
Published Work
Articles and practitioner commentary published outside the firm.
- SAFEs and Section 1202: When Does the QSBS Clock Actually Start?
Tax Notes Federal · Jul 23, 2026
- Let's Be Reasonable: Sourcing California's Restricted Stock Unit Income
Tax Notes State · Mar 2, 2026
- Statutory and Constitutional Limitations on the 20-Year Collection Period Under Revenue and Taxation Code § 19255
CLA Taxation Section 2025 Sacramento Delegation · Oct 24, 2025
- Severable Water Rights As IRC § 170 Charitable Deduction Property
Tax Notes State · Jun 20, 2022
- A Taxonomy Of Tax Professionals
Canadian Accountant · Mar 30, 2021
Tax Professionals
Decision overviews for choosing the right tax advisor when compliance, legal risk, privilege, or controversy strategy may change the answer.
- Are Conversations With Your CPA or Tax Attorney Privileged? When Confidentiality Protects You and When It Fails
When attorney-client privilege, work product, and the CPA privilege protect tax communications, and when confidentiality can fail.
- Tax Attorney vs CPA: Whom Should You Call First?
Choosing the right first call when a tax issue involves compliance, legal risk, privilege, IRS disputes, payroll tax, or cross-border reporting.
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.
- 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.
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.
- When Does an IRS Criminal Investigation Start?
How criminal tax exposure can begin quietly, what IRS CI formally opens, and why willfulness matters more than the size of the tax problem.
Data Analysis
IRS data, trend analysis, and reference material for understanding tax administration and procedure.
- IRS Enforcement Trends: What FY 2021 to 2025 Data Show
A five-year IRS Data Book reference on audit closures, high-income examinations, CP2000 notices, and nonfiler enforcement.
- IRS Appeals and Tax Court Trends: FY 2021 to 2025
A five-year IRS Data Book reference on Appeals workload, Collection Due Process inventory, and the Tax Court docket.
- IRS Penalty Trends: What FY 2021 to 2025 Data Show
A five-year IRS Data Book reference on estimated-tax, failure-to-pay, accuracy-related penalties, and abatements.
- IRS Collection Trends: FY 2020 to 2025 Data
A six-fiscal-year IRS Data Book reference on liens, levies, delinquent-return investigations, payment plans, and offers in compromise.
- IRS Audit Statistics: 2026 Reference Guide
Current IRS audit statistics on examination volume, recommended additional tax, correspondence audits, field audits, and individual audit coverage.
Cases & Court Filings
Selected court work and filings authored by Jason J. Galek.
- Knappe v. United States, Petition for Writ of Certiorari
U.S. Supreme Court · 2013