Real Tax Answers.

Three years is the general rule — IRC § 6501(a), measured from the later of the due date or the date you filed. Six years if you omitted more than 25% of gross income. No limit at all for fraud — or for years where you never filed. And the audit clock is not the collection clock: collection runs ten years from assessment.

Structuring your exit for the after-tax outcome — not the headline number.

Brotman Law represents U.S. persons with foreign accounts, foreign assets, and unreported foreign income who are facing IRS scrutiny or need to come into compliance. We also handle international tax defense for non-U.S. persons with U.S. tax obligations. Here is what that work looks like in practice.

A 15-minute call done right gives you a clear assessment of your situation, a realistic outcome range, and a fee estimate — before you commit to anything.

Payroll tax problems, IRS audits, trust fund recovery penalties, and entity structuring issues. We defend businesses and their owners from the IRS and California tax agencies.

International tax compliance, offshore account disclosure, FBAR defense, asset protection, and proactive tax strategy for individuals with complex financial profiles.

The IRS Fresh Start program is real — but it’s not a single program, and it doesn’t work the way the TV ads describe. Here’s what it actually covers and how each component works in practice.

A tax levy is a legal seizure of your property to satisfy a tax debt. Brotman Law stops active IRS levies, negotiates releases, and resolves the underlying liability so the levy does not return.

We analyze eligibility under every available test — suspension of operations, gross receipts decline, recovery startup status — and build a defensible claim backed by legal documentation.

FBAR non-filing penalties range from $10,000 per account per year for non-willful violations to the greater of $100,000 or 50% of the account balance for willful violations. Brotman Law defends FBAR enforcement proceedings and handles Streamlined Filing Compliance Procedures.

The IRS can ask the State Department to revoke or deny your passport if you owe more than $62,000 in assessed federal tax debt. Here’s what the law actually requires — and what to do about it.

You opened your paycheck and the numbers don’t add up. Here’s how to find out who is garnishing your wages — and what the IRS can do to your paycheck without ever going to court.

Criminal tax cases require a different kind of defense. I handle IRS Criminal Investigation defense, DOJ Tax Division prosecution, grand jury proceedings, and voluntary disclosure — from initial contact through resolution. Attorney and CPA.

I represent high-income taxpayers in FTB residency audits — cases where the Franchise Tax Board challenges whether a taxpayer who claimed to have left California was actually a California resident owing income tax on worldwide income.

California EDD collections attorney representing businesses facing EDD liens, Earnings Withholding Orders, bank levies, and installment agreements. San Diego-based. I handle EDD collection defense and resolution under the California Unemployment Insurance Code.

IRS-CI and DOJ defense for ERC claims under criminal investigation — and the voluntary-disclosure path for claims that should not have been filed.

An IRS audit is a legal dispute, not an accounting problem. We represent San Diego individuals and businesses in correspondence, office, and field examinations — from the first IDR through Appeals and, when it comes to it, Tax Court.

An ERC disallowance letter means the IRS has denied your claim. You typically have 30 days to appeal. Here is what each letter means, what the appeal process looks like, and what documentation actually wins these cases.

Part of our comprehensive guide: The Complete Guide to California CDTFA Collections

Part of our comprehensive guide: The Complete Guide to California CDTFA Collections

Tax law services to help you protect you and your business from California and the IRS and regain your peace of mind.

A strategic overview of how Brotman Law approaches complex tax issues cases.

Using a Charitable Remainder Trust to convert appreciated business stock into a tax-deferred lifetime income stream — when the math works, when it doesn’t, and how to structure it.

What founders need to understand before selling to a private equity buyer — rollover equity, management incentive units, deal structure, and the tax architecture that determines net proceeds.

What to say, what not to say, and the procedure that follows. Revenue Officers do field collections work — not criminal investigations.

Tax disputes happen in every state, not just California. We represent businesses and individuals in state tax controversies across the country — from New York to Texas to everywhere in between.

The False Claims Act carries treble damages and civil penalties up to $27,894 per false claim. We defend businesses facing FCA investigations and civil suits — including ERC fraud referrals, PPP loan allegations, and government contractor matters.

When an IRS civil exam carries criminal exposure — and what to do before the exam becomes a referral.

Letter 6612 gives you 30 days to respond with documentation proving your ERC eligibility under CARES Act Section 2301 — and every word in that response shapes whether the IRS disallows your credit, assesses penalties, or refers your case for criminal investigation. Brotman Law files Form 2848 the day you retain us so the IRS communicates with our team, not with you, from that point forward.

The IRS is offering a limited window to correct improper ERC claims with reduced penalties. We help you evaluate your exposure and choose the right correction path.

We file your Appeals protest, prepare the legal arguments, attend the conference on your behalf, and negotiate a settlement that avoids Tax Court litigation.

21-day hold, then funds transferred. If your account is frozen, you have a narrow window.

An IRS payment plan allows you to pay off your tax debt in monthly installments instead of one lump sum. We help you choose the right plan type, negotiate affordable terms, and stay protected from IRS collection actions while you pay.

I represent individuals and businesses at every stage of IRS collections — from the first notice through CDP hearings, Offers in Compromise, and Tax Court litigation.

An IRS audit is a legal dispute, not an accounting review. The type you’re dealing with tells you a lot about what the IRS thinks it found — and what your response should look like.

If the EDD sent you a Pre-Audit Questionnaire, a payroll tax audit has started — the questionnaire is the auditor’s first fact-gathering move, not paperwork. How you answer it shapes the entire worker-classification examination that follows. Here is what it asks, why each question matters, and how to respond without boxing yourself in.

IRS Criminal Investigation is the only IRS division with law enforcement authority. Special agents are armed federal officers. If CI has contacted you or you suspect an investigation is open, here is how this works.

Tax avoidance is legal. Tax evasion is a federal felony. The distinction turns on one word — willfulness — and what that word means in a criminal tax case is more specific than most people realize.