Tax Audits and Administrative Appeals

The firm has extensive experience with the representation of individuals, shareholders, partners, members, corporations, LLC’s, partnerships, estates, and others in administrative tax audits by the IRS, the California Franchise Tax Board, the California State Board of Equalization, the California Employment Development Department and County Assessor’s Office. As tax agencies such as the IRS, the FTB, The BOE and the EDD have become more aggressive in their audit activity, the need for competent representation by experienced tax professionals has become more important.

The firm handles all types of administrative tax audits by the IRS and state tax agencies, including:

  • Audits involving sensitive issues, where there is the possibility of large amounts of additional taxes and penalties being assessed and/or where there is the possibility of a referral for criminal prosecution
  • Income tax audits by the Internal Revenue Service and the Franchise Tax Board
  • Employment tax audits, including worker classification audits (employee vs. independent contractor) by the Internal Revenue Service and Employment Development Department
  • Sales Tax audits by the California State Board of Equalization
  • Estate and Gift Tax audits by the Internal Revenue Service

The firm also has extensive experience in handling administrative appeals which arise out of income tax audits, employment tax audits, sale and use tax audits, and estate an gift tax audits. For a more detailed description of the firm’s experiencing in handling these types of administrative appeals, please see Tax Penalties.

Several of the firm’s attorneys gained experience representing the IRS by working in the IRS office of Chief Counsel in Washington DC, the Tax Division of the Department of Justice, the Tax Division of the U.S. Attorney’s Office in Los Angles, CA, and/or the Offices of IRS district Counsel in Los Angeles and Laguna Niguel, CA.