Sam Brotman

Founder & Managing Attorney · Brotman Law

Sam Brotman is a tax attorney in San Diego. He started practicing tax law in 2010 and founded Brotman Law in 2013. Since then, he and his team have handled more than 2,500 matters — IRS audits, FTB residency disputes, EDD payroll audits, CDTFA sales tax assessments, criminal tax defense, and tax litigation in U.S. Tax Court and the Court of Federal Claims. The firm has resolved over $1 billion in tax liabilities for its clients.

Most of the people who hire Sam are business owners, high-net-worth individuals, and other attorneys who need someone to handle a tax matter the right way — calmly, technically, and without manufactured drama. The firm’s clients are sophisticated. They already know the matter is serious; they don’t need a marketing pitch about it. They need someone who can read the file, identify the controlling issue, and tell them what the realistic outcomes look like.

How Sam works with clients

Sam takes the position that an IRS or California state tax problem is a legal dispute with the government — not an accounting problem. Most tax controversies turn on procedure, evidence, and the application of specific statutory authority, not on bookkeeping. Treating an audit as a legal matter from the first IRS contact is what separates good outcomes from avoidable ones.

The firm’s approach is built on three ideas:

Technical credibility over emotional urgency. Sophisticated clients respond to specific citations and procedural mastery, not pressure. Sam will tell a client what the IRS is actually empowered to do under the relevant statute, what the realistic ranges of outcomes look like, and what the next 30, 60, and 90 days will involve. Then the client decides how to proceed.

Calm execution over reactive scrambling. Most tax matters do not need to move at emergency speed. They need to move correctly. Sam runs the firm with deadlines tracked centrally, work product reviewed before it goes out, and clients informed about what we’re doing and why — without the firm performing busy-ness as a substitute for results.

Give clients enough information to make their own decisions. Sam does not believe in withholding the basis for a recommendation. If we are choosing between an Offer in Compromise and a partial-pay installment agreement, the client should understand the Reasonable Collection Potential analysis, the Collection Statute Expiration Date implications, and the realistic odds on each path. Then the decision is theirs.

Sam handles most matters personally on the front end — the initial consultation, the assessment of the case, and the strategy. From there, he brings in the right team member for execution. The firm has dedicated attorneys for EDD audits, CDTFA sales tax, FTB residency and collections, IRS collections, ERC audit defense and litigation, and criminal tax defense. Sam stays involved on every active matter through senior review and direct client communication when the matter calls for it.

Education and credentials

Sam earned his J.D. from the University of San Diego School of Law and his LL.M. in Taxation from the University of San Diego — the latter being a graduate degree dedicated entirely to tax law. He also holds an MBA, which is unusual among tax attorneys and shapes how he thinks about transactions and business-owner clients.

He is admitted to:

The California Bar — State Bar No. 274966 (admitted 2010)
The United States Tax Court
The California Superior Court

He has been recognized as a Super Lawyer in tax law every year since 2016.

Practice areas

Sam’s practice spans federal and California state tax controversy, transactional tax strategy, and tax litigation. The major areas:

IRS audit defense and IRS Appeals. Correspondence, office, and field audits across individual, business, and high-net-worth examinations. Includes eggshell audits and audits with criminal exposure.
U.S. Tax Court and Court of Federal Claims litigation. Petitions filed after a 90-day letter, refund suits, and ERC refund litigation under 26 U.S.C. § 7422.
California Franchise Tax Board (FTB) matters. Personal income tax audits, residency audits under Cal. R&TC § 17041, FTB collections defense, and Offer in Compromise under Cal. R&TC § 19443.
California sales tax (CDTFA) audits and appeals. Audit defense, settlement negotiation, and the appeals process through the Office of Tax Appeals.
California payroll tax (EDD) audits. Including worker classification under AB 5 and the Borello test, trust fund assessments, and the EDD’s audit and appeals procedure under the California Unemployment Insurance Code.
Employee Retention Credit (ERC) work. ERC eligibility analysis, audit defense, and refund litigation. The firm has handled ERC matters from the eligibility stage through the courthouse.
Criminal tax defense. IRS Criminal Investigation matters — unreported income, employment tax fraud, FBAR and offshore account violations, and audits with criminal exposure.
Tax strategy and planning. Entity structuring, business sale tax planning, qualified small business stock under IRC § 1202, and exit planning for closely held businesses.

Representative matters

A few representative outcomes from the firm’s work:

$2.1M IRS tax debt settled for $185K — Offer in Compromise resolution for an individual client.
$800K+ in ERC credits preserved after an IRS disallowance notice, through administrative appeal and refund-claim work.
$1.2M in capital gains tax saved on a business sale through pre-transaction structuring.
Six-figure FTB assessment reduced by 85% — residency audit defense for a high-net-worth California client.
Criminal tax referral resolved with no charges filed through eggshell audit defense and proactive engagement with IRS Criminal Investigation.

Full case studies are at /results/.

Recognition

Super Lawyer — Tax Law — every year since 2016.
Inc. Magazine — Brotman Law named one of the 8 fastest-growing legal firms in America.
Forbes Business Council — member; Sam contributes on tax strategy and law-firm operations.
Inc. 5000 — multiple appearances on the list of fastest-growing private companies in America.

Memberships

State Bar of California — admitted 2010, State Bar No. 274966 (profile)
ABA Tax Section — American Bar Association, Section of Taxation
California Lawyers Association — Taxation Section
San Diego County Bar Association
Forbes Business Council — member

How the firm is built

Brotman Law is not a solo practice. The firm has dedicated attorneys for each of the major practice lines:

Carlos Gomez — Senior Attorney, tax optimization and California state tax (EDD, CDTFA, FTB).
Tara Pullano — Senior Attorney, ERC claim development and litigation.
Sahar Bijan, Rojin Bijan, Ricardo Laureano, Jialin Dykstra — Associate Attorneys handling IRS audit defense, ERC matters, IRS collections, and tax research.

Sam built the firm intentionally — with people who specialize, share work product review, and treat clients consistently. The reason most clients work with Brotman Law for years after the original matter resolves is that the firm is built to handle whatever comes next.

Beyond the practice

Sam started Brotman Law in San Diego in 2013 — three employees, a small office on Saratoga Avenue in Ocean Beach, a laid-back vibe, and a killer ocean view. The firm has since moved twice as it grew, most recently to a Del Mar–area office on High Bluff Drive in November 2025. San Diego is part of why Sam built the firm here rather than taking a big-firm job in another city.

Where to find Sam

Book a free 15-minute call

Most matters start with a 15-minute conversation. Sam takes those calls himself when his schedule allows; otherwise a senior member of the team will. Book a call →

Practice Areas

Where Samuel Handles Matters

To discuss a specific matter, book a free 15-minute call.