Tax Collection and Appeals
The firm represents both individuals and companies facing tax collection by the Internal Revenue Service, California Franchise Tax Board, and the state taxing agencies. We are known by our clients for saving substantial amounts of money and devising innovative solutions to resolve complex tax problems. A sampling of our work includes:
- Negotiating and obtaining installment agreements or offers in compromise.
- Appealing an IRS collection action (such as a levy or the filing of a tax lien) to the IRS Office of Appeals through the Collection Due Process or Collection Appeals Program.
- Seeking a release or withdraw of a notice of federal tax lien or levy and a return of the client’s money or property.
- Representing clients, who have received an IRS collection summons seeking the production of books and records or testimony.
- Trust fund recovery penalty cases where the IRS seeks to assess a penalty against an individual.
- Preparing and negotiating claims for innocent spouse relief.
- Handling clients with delinquent or unfiled tax returns or unreported income.
- Representing clients who seek audit reconsideration to contest the amount due to the IRS.
- Counseling clients who seek to discharge taxes through bankruptcy
The Office of Tax Appeals (OTA)
We handle the representation of taxpayers who are involved in administrative appeals from the California Franchise Tax Board (FTB) or the California Department of Tax and Fee Administration (CDTFA). A taxpayer may file an appeal once the agency issues a Notice of Action or Appeals Bureau Decision with an “appeal-by” date.
The Office of Tax Appeals (OTA) is an independent and impartial appeals body created by the Taxpayer Transparency and Fairness Act of 2017. The office was established to hear appeals from California taxpayers regarding various taxes and fees administered by the California Department of Tax and Fee Administration and the Franchise Tax Board.
Tax disputes involving personal income, corporate franchise and income, sales and use, excise and other taxes and fees are decided by a three-member panel of Administrative Law Judges, each of whom is an expert in tax law. The office is independent of the state’s tax agencies. Appeals are heard in Sacramento, Fresno and Los Angeles.
The Office of Tax Appeals is the successor in interest to the State Board of Equalization (BOE).