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Federal & California Tax Audits, Appeals and Litigation

Federal and California Tax Audits and Appeals

The firm has substantial experience in representing clients who are the subject of a civil examination by the Internal Revenue Service or state taxing agencies such as the California Franchise Tax Board.  A sampling of our work includes cases involving:

  • Prepaid forward sales contracts

  • Substantiation of business expenses

  • Stock sales

  • Section 1031 exchanges

  • Taxation of financial instruments

  • Civil fraud penalty

  • Unreported business income

  • Apportionment and allocation of income for California taxation purposes

  • Issues involving partnership taxation

  • Net operating losses from real transactions

  • Employment tax disputes

  • California sourcing rules and nonresidency disputes


If a case is unresolved at the examination level, we strategically appeal the proposed adjustments and seek to negotiate a settlement at the IRS Office of Appeals.  Our attorneys are known for our ability to write clearly and effectively present evidence and arguments to negotiate a favorable settlement on behalf of our clients, and avoid costly litigation in Tax Court whenever possible.


We also have substantial experience with the California Franchise Tax Board.  The firm is uniquely located in California, and the founding member, Steven L. Walker, formerly worked at the California Franchise Tax Board.  We have handled several complex and sensitive individual and business cases at the audit, protest and settlement levels.  Our work includes:

  • Representing clients during audit, including reviewing audit plan, attending opening conference, responding to information document requests, managing the fact and information gathering, and resolving issues at the audit level whenever possible.

  • Preparing and filing a written protest letter in response to a Notice of Proposed Assessment and representing clients at protest hearings.

  • Negotiating settlements with the Settlement Bureau of the California Franchise Tax Board.

  • Appealing a Franchise Tax Board decision to the State Board of Equalization


Tax Litigation

Our tax litigation experience encompasses virtually every type of case before the United States Tax Court including companies, investors, individuals, partners, trusts, and estates. Our lawyers resolve cases through negotiated settlement with the IRS Office of Appeals, by trial and, if necessary, by appeal. We aggressively seek to minimize our clients tax liabilities without compromising ethical principles. We have earned a reputation among clients for understanding the complex rules of tax practice and procedure and solving our clients’ problems in unique and innovative ways. The firm is known and well respected by government tax officials, which benefits our clients in resolving complex tax controversies.


U.S. Tax Court practice includes:

  • Deficiencies determined by the Commissioner with respect to income, estate, or gift tax cases

  • Claims for relief from joint and several liabilities (innocent spouse cases)

  • Worker classification cases (i.e., independent contractor or employee)

  • Collection Due Process cases


Tax litigation in federal district court includes:

  • Refund litigation

  • Challenges to the enforcement of IRS summonses

  • Suits related to wrongful levy

  • Review of IRS collection actions before levy on principal residence

  • Suits to reduce tax assessments to judgment

  • Interpleader, quiet title, foreclosure, or other actions involving property in which the IRS may claim an interest

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