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:

• 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

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.