The Firm handles all types of tax cases, including providing advice on minimizing taxes, analyzing the tax implications of transactions, preparing tax returns, representing clients being audited, collection matters and suing the IRS in Court.
The Firm handles cases involving just about every type of tax issue ranging from providing advice on the taxability or tax implications of a transaction to representing clients involved in disputes over the amount of taxes owed and/or the ability of clients to pay the taxes they agree they owe. I use my real estate, bankruptcy and litigation expertise to help my clients develop comprehensive solutions to the tax issues or problems they face so they are able to avoid having to consult with multiple attorneys in various disciplines in order to get the information they need.
The Firm regularly provides tax advice regarding how to minimize taxes for a particular transaction as well as how to plan ahead to minimize the tax implications from an impending event like the sale or foreclosure of real estate. In many cases, Clients have been referred to me by their attorneys, CPA's and real estate agents. Taxes are steadily increasing and becoming more complicated and more pervasive so it is really important to ensure that something you are about to do which makes sense legally or financially will not leave you with a large, unexpected tax bill.
Tax Audits and other Contested Substantive Tax Disputes
The Firm helps clients with all types of disputes with the IRS from providing advice on how to respond to a simple "letter" audit or notice of proposed change to representing Clients involved in both criminal and civil tax disputes throughout the administrative and judicial process. We have successfully litigated against the IRS in Tax Court, District Court, Bankruptcy Court and even the Ninth Circuit Court of Appeals. While I am typically able to resolve most contested tax cases at the Audit or Administrative Appeal level without ever going to Court, the fact that I am ready, able and willing to take that step usually means that the IRS will prefer to settle and move on to their next case.
We provide comprehensive help for clients who owe taxes they are not able to pay including assistance with all of the various IRS programs available as well as helping clients get rid of taxes in bankruptcy. IRS programs include monthly installment agreements, hardship deferrals on collection (the IRS agrees to temporarily suspend collection) and offers in compromise (the IRS agrees to "settle" the tax debt for less than the amount owed.) Bankruptcy can be an attractive option for Clients who either do not qualify for any of the administrative programs or who have other financial difficulties.
The IRS currently relies on many elements from the "disposable monthly income" calculations used in Bankruptcy Court in determining how much and how quickly it will require a taxpayer to pay. Although the standards for these programs have been recently relaxed, the lack of adequate customer service personnel and resources at the IRS makes it very difficult to get your case heard unless you are intimately familiar with the internal procedures and the administrative appeal system within the IRS. We are typically able to resolve nearly all collection cases at the administrative level but litigation and the threat of litigation are occasionally needed to obtain a fair resolution.
Non-Tax Related Matters
The Firm provides a variety of other non-tax related legal services for California residents including real estate, estate planning, bankruptcy and litigation.