Tax Audits and Administrative Appeals
The firm has extensive experience representing individuals, corporations, partnerships, LLC’s and estates and trusts in administrative tax audits and disputes with the IRS, California Franchise Tax Board, California State Board of Equalization, California Employment Development Department and County Assessor’s Office.
We pride ourselves on resolving cases as early in the process as possible in order minimize our clients’ tax liability and reduce ongoing expenses. We have the depth of experience and knowledge to handle a case through all administrative and legal channels while at the same time pursuing negotiations with government personnel to reach a satisfactory resolution.
We routinely handle sensitive tax cases that may involve substantial liabilities or potentially lead to a criminal referral for tax fraud or evasion.
Recent cases include a comprehensive payroll tax audit to determine worker classification, foreign bank account report (FBAR) penalty investigations and appeals, complex estate and gift tax audits, effectively defending trust fund recovery penalty assessments, defending a criminal tax investigation where there were unfiled tax returns for multiple entities.