Administrative Tax Appeals

The firm has extensive experience in representing individuals, shareholders, partners, members, corporations, LLC’s, partnerships, estates, and others in administrative and quasi-judicial tax appeals, including appeals arising as the result of audit activity and appeals arising as the result of collection activity. The firm handles these types of audit appeals involving both the IRS and state tax agencies including:

  • Administrative appeals before the IRS Office of Appeals arising out of income tax audits, employment tax audits, estate and gift tax audits, excise tax audits, and other types of tax audits. This include the use of Fast Track Settlement, Fast Track Mediation, Post-Appeals Mediation and similar types of programs offered by the IRS
  • Administrative appeals in income tax matters before the Franchise Tax Board Protest Unit
  • Administrative appeals in income sales and use tax matters before the Board of Equalization hearing officers
  • Administrative appeals before the five-member California State Board of Equalization in income tax and sales and use tax matters
  • Administrative appeals in property tax matters

The firm also handles administrative appeals before the IRS Office of Appeals relative to collection activity including:

  • Collection Due Process (“CDP”) appeals involving challenges to proposed levy action
  • Collection Due Process (“CDP”) appeals involving challenges to the filing of Notices of Federal Tax Lien
  • Equivalent hearings involving challenges to proposed levy action and to the filing of Notices of Federal Tax Lien
  • Collection appeals process (“CAP”) hearings involving challenges to proposed or existing collection action