Taylor Nelson Amitrano LLP

Taylor Nelson Amitrano LLP Taylor Nelson Amitrano LLP specializes in civil and criminal tax controversies.

In an article published last week, Bloomberg Law examined the government’s appeal in Kwong v. United States and the pote...
05/26/2026

In an article published last week, Bloomberg Law examined the government’s appeal in Kwong v. United States and the potentially significant impact the case may have on COVID-era tax refund claims, interest assessments, penalties, and filing deadlines. The article discusses how the Kwong decision is already influencing litigation nationwide involving Section 7508A and pandemic-related tax controversies.

As part of Bloomberg Law’s coverage, Taylor Nelson Amitrano LLP Managing Partner Jonathan Amitrano, was interviewed regarding the broader implications of the litigation, including the likelihood of increased refund claim activity as applicable refund claim deadlines approach. Learn more about Jonathan’s expertise by visiting his bio at https://www.taylorlaw.com/attorneys/jonathan-t-amitrano.

In Kwong, the Court of Federal Claims interpreted the 2019 version of Section 7508A(d) of the Internal Revenue Code and held that the COVID-19 disaster period postponed the taxpayer’s deadline to file a refund suit. Bloomberg Law’s article discusses how that reasoning is now being invoked in other contexts, including challenging pandemic-era interest and penalty assessments.
Read the full Bloomberg Law article here at https://news.bloombergtax.com/daily-tax-report/billions-in-covid-era-tax-refunds-are-at-stake-as-us-appeals.

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As we observe Memorial Day, Taylor Nelson Amitrano LLP honors and remembers the men and women who gave their lives in s...
05/22/2026

As we observe Memorial Day, Taylor Nelson Amitrano LLP honors and remembers the men and women who gave their lives in service to our country.

Today, we reflect on the sacrifices made by generations of Americans and extend our gratitude to those who served and to the families who continue to carry their legacy forward.

We wish everyone a meaningful and peaceful Memorial Day.

Taylor Nelson Amitrano LLP is delighted to announce that Minh “Dennis” Nguyen has been selected as a recipient of the p...
05/11/2026

Taylor Nelson Amitrano LLP is delighted to announce that Minh “Dennis” Nguyen has been selected as a recipient of the prestigious American Bar Association Section of Taxation John S. Nolan Fellowship for the 2026–2027 term.

The Nolan Fellowship is a highly competitive national program that recognizes emerging leaders in tax law and provides a platform for fellows to engage deeply with the ABA Tax Section’s substantive work and leadership. Dennis’s selection reflects his commitment to excellence in tax controversy and his growing contributions to the profession.

We congratulate Dennis on this well-deserved honor and look forward to his continued impact through the program. To learn more about Dennis’ background and experience, visit https://www.taylorlaw.com/attorneys/minh-dennis-nguyen.

To learn more about our firm’s tax controversy services, visit www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is pleased to share that associate attorney Michael Romero will be speaking next week at an ...
05/07/2026

Taylor Nelson Amitrano LLP is pleased to share that associate attorney Michael Romero will be speaking next week at an upcoming continuing education webinar hosted by the California Society of Enrolled Agents (CSEA).

On May 12, 2026, at 6:00 PM (Pacific), Michael will present a session entitled “Representing Businesses with No Records.” The program will cover practical methods for reconstructing incomplete business records, evaluating when estimates may be used to support income and deductions, and applying the Cohan Rule effectively—along with its limitations—in audit and tax controversy settings.

This webinar offers continuing education credit across multiple disciplines:
IRS: 2 hours - Federal Tax Topics
CTEC: 2 hours - Federal Tax Topics
CA Bar: 1.75 hours - Taxation Law
CPA (CA): 2 hours - Taxes (Self-Reporting)

To take advantage of this insightful session presented by an experienced tax controversy attorney, register here:
https://www.csea.org/iCore/Events/Event_Display.aspx?EventKey=CSEA260512&WebsiteKey=64198a07-d0cb-4356-9de9-7fec757d74f6

Taylor Nelson Amitrano LLP attorneys bring experience representing taxpayers before the IRS and California taxing authorities, including in cases where records are limited and reconstruction is critical.

To learn more about our firm’s tax controversy services, please visit www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is excited to announce that Managing Partner Jonathan Amitrano and Kurt Kawafuchi have author...
05/06/2026

Taylor Nelson Amitrano LLP is excited to announce that Managing Partner Jonathan Amitrano and Kurt Kawafuchi have authored an article for Kala Magazine and the Hawaii Society of Certified Public Accountants, now published in its May 2026 newsletter.

In “Federal Interest and Penalty Refund Opportunities After Kwong and Abdo,” the authors examine how I.R.C. § 7508A(d) and recent decisions in Kwong v. United States and Abdo v. Commissioner may extend tax deadlines tied to the COVID-19 disaster period—creating potential opportunities for interest and penalty refunds or abatements.

The article underscores a key takeaway for practitioners: taxpayers may have viable claims where deadlines were effectively postponed under a mandatory statutory framework.

We are proud to contribute to the ongoing dialogue on this evolving area of tax law. To learn more about our firm’s tax controversy services, visit www.taylorlaw.com. To learn more about Jonathan’s background and experience, visit https://www.taylorlaw.com/attorneys/jonathan-t-amitrano.

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Taylor Nelson Amitrano LLP is delighted to share that Managing Partner Jonathan Amitrano will be presenting at the Amer...
05/05/2026

Taylor Nelson Amitrano LLP is delighted to share that Managing Partner Jonathan Amitrano will be presenting at the American Bar Association Section of Taxation’s 2026 May Tax Meeting in Washington, DC.

On Friday, May 8, 2026, Jonathan will serve as moderator for the 9:50 AM program, “The Impact of Kwong and Abdo: Refund Opportunities and Future Implications.” This session will examine recent developments affecting interest and penalty accruals during the COVID-19 disaster period and the resulting opportunities for taxpayers and practitioners. Later that day, Jonathan will also serve as a panelist for the 4:25 PM program, “Procedural Pathways for Challenging Assessed Liabilities.” This discussion will focus on key strategies for challenging liabilities within and outside of Collection Due Process Proceedings.

Our firm’s ongoing support of the ABA and its educational focus and mission demonstrates our commitment to our clients and to the legal profession in general.

To learn more about the meeting and register, please visit:
https://events.americanbar.org/event/5be6e522-0d49-48a4-aa9c-8fa7e8aaf7dc/summary
To learn more about our firm’s tax controversy services, please visit www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is pleased to share that several of its attorneys will present at the California Lawyers Ass...
04/30/2026

Taylor Nelson Amitrano LLP is pleased to share that several of its attorneys will present at the California Lawyers Association (CLA) Taxation Section’s 2026 Washington, D.C. Delegation, May 3–5, 2026. The CLA D.C. Delegation allows California tax attorneys and federal officials to have focused dialogue on federal tax policy and administration. We are honored to have our attorneys support and participate in this important event.

For the fourth consecutive year, multiple firm attorneys will contribute to the program presenting the following papers:
• Rami Khoury and Jinsoo Lee — “Proposal to Amend I.R.C. § 6651(b)(1) to Recognize Post-Due-Date Payments in Computing the Failure-To-File Penalty”
• Robert Russell and Minh “Dennis” Nguyen — “Reforming Letter 105C Refund Denial Procedures and IRS Section 6532 Limitations: A Proposal for Pre-Disallowance Appeals Review and Automatic Extensions”
• Jonathan Amitrano and Phillip Colasanto — “Proposed Changes to Collection Due Process Regulations to Ensure Collection Due Process Rights to All Parties Against Whom the Service Seeks to Levy”

Learn more about our firm’s tax controversy services at www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is delighted to continue its longstanding support of the American Bar Association Section o...
04/29/2026

Taylor Nelson Amitrano LLP is delighted to continue its longstanding support of the American Bar Association Section of Taxation’s 2026 May Tax Meeting taking place May 7–9, 2026, in Washington D.C., as a Ruby Sponsor.

As part of this sponsorship, the firm is honored to serve as the named sponsor of the Civil and Criminal Tax Penalties Committee Luncheon—one of the meeting’s most anticipated events. Please join us for this special award luncheon on Friday, May 8, 2026. Hosted by the Civil and Criminal Tax Penalties Committee, the luncheon brings together leading tax attorneys and professionals to recognize excellence in the field and engage in meaningful discussion on civil and criminal tax enforcement.

Early registration is recommended, as this event is expected to sell out. To learn more about the meeting and register, please visit:
https://events.americanbar.org/event/5be6e522-0d49-48a4-aa9c-8fa7e8aaf7dc/summary

Taylor Nelson Amitrano LLP brings extensive experience when representing taxpayers in complex civil and criminal tax controversy matters before the IRS and California taxing authorities. To learn more about our tax controversy services, please visit www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is proud to sponsor the Networking Reception at the California Lawyers Association (CLA) Ta...
04/28/2026

Taylor Nelson Amitrano LLP is proud to sponsor the Networking Reception at the California Lawyers Association (CLA) Taxation Section’s 2026 Washington, D.C. Delegation on Monday, May 4, 2026.

The CLA D.C. Delegation is a cornerstone event for California tax practitioners, bringing together attorneys, government officials, and policymakers for substantive discussions on federal tax policy and administration. The program provides a unique opportunity for direct engagement with the Revenue Service, U.S. Department of the Treasury, and congressional staff on the most pressing issues shaping today’s tax landscape.

Our firm is honored to support this important forum and the collaboration it fosters within the tax community.

Learn more about our firm’s tax controversy services at www.taylorlaw.com.

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Taylor Nelson Amitrano LLP is pleased to announce that Senior Counsel Robert Russell and associate attorney Dennis Nguy...
04/16/2026

Taylor Nelson Amitrano LLP is pleased to announce that Senior Counsel Robert Russell and associate attorney Dennis Nguyen will participate in an upcoming American Bar Association webinar, “Taxing the Forecast: A Closer Look at Prediction Markets.” Robert will serve as a speaker, with Dennis moderating the program.

Scheduled on April 21st at 1:00 EDT, this 90-minute webinar will examine the emerging tax implications of prediction markets, offering timely insights into how these evolving platforms intersect with existing tax frameworks and enforcement considerations.

Register here:
https://learningcenter.americanbar.org/courses/129749

Taylor Nelson Amitrano LLP attorneys provide guidance on complex and developing areas of tax law, advising clients on both administrative matters as well as litigation involving the IRS and state taxing authorities. To learn more about our firm’s tax controversy services, visit https://www.taylorlaw.com/.

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Taylor Nelson Amitrano LLP is delighted to share that Managing Partner Jonathan Amitrano was recently quoted in an arti...
04/14/2026

Taylor Nelson Amitrano LLP is delighted to share that Managing Partner Jonathan Amitrano was recently quoted in an article published in Tax Notes. The article examines the evolving litigation landscape surrounding the COVID-19 disaster and the mandatory postponement period under I.R.C. § 7508A.

In recent and future litigation, Courts are interpreting Section 7508A and whether the COVID-19 disaster extended certain tax deadlines to July 10, 2023. This issue is now surfacing in both civil and criminal tax matters. In United States v. Goldstein, the issue focuses on whether those extensions could affect key elements of certain tax-related charges.

In the article, Jonathan emphasized that where the existence and timing of a legal duty are genuinely in dispute, establishing willfulness in criminal tax cases becomes significantly more difficult.

Taylor Nelson Amitrano LLP values the opportunity to engage in these nuanced, high-stakes discussions shaping tax controversy law.

To learn more about Jonathan’s background and experience in tax controversy law, visit his bio: https://www.taylorlaw.com/attorneys/jonathan-t-amitrano

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1900 Main Street, Suite 650
Irvine, CA
92614

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Monday 9am - 5pm
Tuesday 9am - 5pm
Wednesday 9am - 5pm
Thursday 9am - 5pm
Friday 9am - 5pm

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