Since 2003
Since 2003
Since 2011
Since 2011
Since 2008
Since 2005
2014 - Current
Wilson Tax Law Group, Newport Beach, California
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.
2011 - 2014
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.
2010 - 2011
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.
2008 - 2010
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.
2006 - 2008
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.
2003 - 2006
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.
2002 - 2003
LL.M. (2003) | Masters in Law Taxation
1999 - 2002
J.D. (2002) | Law
1995 - 1999
B.S. (1999) | Business
American Society of Legal Advocates
Finance Monthly
Orange County Lawyer Magazine
Daily Journal
OC Register
State Bar of California
Legal Aid Society of San Diego
Deloitte & Touche
Deloitte & Touche
State Bar of California
Legal Aid Society of San Diego
Deloitte & Touche
Univesity of San Diego
Business Taxes, Criminal Tax Litigation, Estate Tax Planning, Income Taxes, International Taxes, Payroll Taxes, Property Taxes, Sales Taxes, Tax Appeals, Tax Audits, Tax Planning
Criminal Appeals, Drug Crimes, Expungement, Fraud, Gun Crimes, Internet Crimes, Sex Crimes, Theft, Violent Crimes
Administrative Law, Election Law, Government Contracts, Government Finance, Legislative & Government Affairs
Civil Appeals, Federal Appeals
Chapter 11 Bankruptcy, Chapter 13 Bankruptcy, Chapter 7 Bankruptcy, Debt Relief
Human Rights, Imports & Exports