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ERC Refund Lawsuit Deadline Calculator

If the IRS disallowed your ERC claim, you generally have two years from the date on the disallowance notice to […]

San Diego IRS Collections Attorney

IRS collections in San Diego runs on the same federal rulebook as everywhere else — but it is enforced by […]

Construction Sales Tax Audits: Materials, Fixtures, and Regulation 1521

CDTFA audits of construction contractors turn on a rule that exists nowhere else in sales tax: under Regulation 1521 you […]

FTB Tax Attorney for Audits, Collections, and Residency

The Franchise Tax Board is not the IRS, and treating it like the IRS is how California taxpayers get hurt. […]

San Diego IRS Audit Defense

An IRS audit of a San Diego business or individual is a legal dispute with the federal government, and where […]

San Diego Criminal Tax Defense

Criminal tax cases against San Diego taxpayers are charged downtown — federal ones by the U.S. Attorney for the Southern […]

San Diego EDD & Payroll Tax Audit Defense

EDD audits hit San Diego’s contractor-heavy economy harder than almost any other enforcement program: construction trades, salons, gyms, restaurants, and […]

San Diego Sales Tax & CDTFA Audit Defense

San Diego runs on exactly the businesses the CDTFA audits hardest: restaurants, bars, contractors, auto dealers, and border-adjacent retail. If […]

CUIC § 1735: When the EDD Comes After You Personally

CUIC § 1735 lets the EDD assess a corporation’s or LLC’s unpaid payroll taxes against the officers and owners who […]

The EDD Notice of Assessment and the 30-Day Petition for Reassessment

The Notice of Assessment from the Employment Development Department (EDD) is the bill that closes a payroll tax audit, and […]

The EDD Worker Classification Finding: What the ABC Test Means for Your Assessment and How to Contest It

The worker classification finding from the Employment Development Department (EDD) is the auditor’s conclusion that the people you paid as […]

ERC Enforcement by the Numbers: Inside a 273-Matter Docket

These are the current numbers from Brotman Law’s ERC controversy docket — one of the larger ERC disallowance and litigation […]

The IRS Assigned a Revenue Officer. Here’s What Just Changed.

A revenue officer assignment means your case left the computer. ACS sends letters; a revenue officer builds a file on […]

You Owe the IRS Six Figures. Which Tool Actually Fits?

If you owe the IRS somewhere between $50,000 and $500,000, you have four real options: an installment agreement, an Offer […]

Restaurant Sales Tax Audits: Beating the CDTFA’s Model of Your Restaurant

Restaurants are the CDTFA’s favorite audit target because cash plus estimated methods equals adjustable numbers. If your restaurant is under […]

Petition for Redetermination: The 30 Days That Decide a CDTFA Case

A Notice of Determination from the CDTFA starts a 30-day clock. File a petition for redetermination inside it and the […]

CDTFA Responsible Person Liability: The Dual Determination Letter and How Owners Fight It

A dual determination from the California Department of Tax and Fee Administration (CDTFA) is a Notice of Determination that assesses […]

CDTFA Audit Attorney

A CDTFA audit attorney works the part of a California sales tax audit that decides the number: the method the […]

San Diego Tax Attorney

Brotman Law is a San Diego tax firm that represents businesses and individuals against the IRS, the FTB, the EDD, […]

Offer in Compromise Attorney

An offer in compromise is a settlement with the IRS for less than you owe under section 7122 of the […]

The IRS Fresh Start Program: What It Actually Is (and Isn’t)

The IRS Fresh Start Program is not a program you apply to. It is a name the IRS gave in […]

How Far Back Can the IRS Audit You?

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.

Business Sale Tax Attorney

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

California Payroll Tax Attorney

California Sales Tax Attorney

ERC Disallowance Letter 105-C

ERC Refund Tracker

San Diego International Tax Attorney

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.

Tax Attorney Consultation

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.

Tax Attorney for Business Owners

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.

High Net Worth Tax Attorney

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: What It Actually Is (and Isn’t)

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.

FBAR Attorney

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.