An IRS audit of a San Diego business or individual is a legal dispute with the federal government, and where it can end up — appeals, Tax Court’s San Diego trial sessions, or the Southern District — should shape how it is handled from the first IDR.
If your business is in San Diego County, our San Diego CDTFA sales tax attorney page explains how we handle sales tax audits and collections here.
The audit itself follows the same federal playbook everywhere: correspondence exams for narrow issues, office and field exams for businesses, the Information Document Request cadence, Form 4549 findings, the 30-day letter, and appeal rights that most taxpayers never properly use. What is local is the fact pattern and the forum. Our San Diego audit book runs to the county’s economy — professional practices, contractors, real estate operators, biotech and defense-adjacent contractors with credit and R&D issues, and business owners whose returns drew the wrong kind of attention. When a case does not settle at exam or appeals, the U.S. Tax Court hears San Diego cases in San Diego — petition rights run 90 days from the Notice of Deficiency, and preserving them costs nothing.
The three decisions that decide most audits
Scope: what you agree to produce, and when — over-production is the most common unforced error we clean up. The interview: who talks to the agent, and with what preparation; with a Form 2848 on file, often nobody from your side of the table has to. The exit: whether to agree, go to appeals, or petition Tax Court — a math-and-hazards decision, not a mood. Where an audit carries criminal undertones — cash businesses, amended-return patterns, prior-year problems — it is an eggshell audit and gets handled under a different protocol entirely.
Since 2013 we have represented more than 400 clients in audits, eliminated over $100M in penalties and interest, and handled the follow-on — collection alternatives when the bill is real, appeals when it is not.
San Diego IRS audit under way?
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Related: IRS audit defense practice · if an agent visits your business · all San Diego practice areas.
By Sam Brotman, JD, LLM, MBA — managing attorney, Brotman Law. CA Bar No. 274966. Last updated August 29, 2026.
