Case law updates and fundamentals in California tax controversy — MCLE for attorneys and CE for California CPAs.
Three decisions from this month that change how audits and Tax Court petitions should be handled.
[Case] v. Commissioner, T.C. Memo. 2026-__ · [Case] v. Commissioner, 167 T.C. No. __ · United States v. [Name] (9th Cir. 2026)
PreviewThe audit process from initial contact through Appeals, and where a practitioner's involvement changes the outcome.
PreviewFiling a petition, the stipulation process, and what distinguishes Tax Court practice from other federal litigation.
PreviewWhy attorney-client privilege protects tax advice that a CPA engagement cannot, and how a Kovel arrangement extends it.
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Thomas Ogden is a Certified Specialist in Appellate Law and in Taxation Law, certified by the State Bar of California Board of Legal Specialization, with more than 22 years in practice. He served as a Tax Law Advisory Commissioner to the State Bar of California's Board of Legal Specialization. His tax practice is controversy work: IRS and Franchise Tax Board examinations, Appeals, the Office of Tax Appeals, refund litigation, and the U.S. Tax Court, together with criminal tax defense and cross-border disputes. Much of his work comes by referral from CPAs and enrolled agents who want counsel involved before a civil matter becomes something else. He is also a solicitor (currently non-practising) in England and Wales and in Ireland.
Practice sites: appellate practice · tax controversy practice · Email: thomas@ogden.law