Real Tax Answers.
For the Problems You're Actually Facing.
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.
From IRS audits to tax debt resolution to proactive planning, Brotman Law provides comprehensive tax relief services for individuals and businesses throughout California. One firm, every tax solution.
A lien is a legal claim against your assets. A levy takes them. Here’s how to tell the difference and what you can do about a lien.
A notice of deficiency is the IRS’s formal determination that you owe additional tax. From the date on the notice, you have 90 days to file a petition in U.S. Tax Court. That deadline is absolute.
Brotman Law represents businesses and individuals named as defendants in qui tam lawsuits — not relators. If a whistleblower has filed a False Claims Act complaint against you, or you believe one has been filed, this is where to start.
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.
A continuous levy takes a portion of your paycheck every pay period until resolved. Unlike a bank levy, it doesn’t stop on its own.
An IRS information document request — issued on Form 4564 — is one of the primary tools agents use during an examination. You are not required to produce every document requested. But ignoring an IDR has real consequences. Here’s how to respond strategically.
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.
Deferring capital gains on California investment property — and handling the mechanics, the QI, and the FTB clawback trap the right way.
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.
An Offer in Compromise settles tax debt for less than you owe — when the numbers support it. We run the analysis honestly, file offers that can actually be accepted, and defend them through appeal.
The U.S. Tax Court is the one forum where you can dispute the IRS before paying. We petition, litigate, and settle Tax Court cases for San Diego taxpayers — and prepare every case as if it will be tried.
EDD payroll tax penalties stack in layers. The base assessment includes unpaid UI, SDI, ETT, and PIT withholding across up to 12 quarters , then CUIC §1126 adds 15% for late filing, §1127 adds another 15% for negligence, and §1128 can add 50% for fraud — before Labor Code §226.8’s per-worker civil penalties even apply.
When the IRS denies your ERC claim or refuses to process it, litigation is the path that forces them to act. We file ERC lawsuits in federal court and Tax Court to recover the refunds our clients are owed.
The short answer is yes — federal prison is a real outcome for tax crimes. The longer answer is that criminal prosecution requires willfulness and an affirmative act. Most people who owe back taxes, or who haven’t filed, are in civil territory, not criminal.
If you owe the IRS more than you can pay in full, you have options. Four resolution paths exist — and the right one depends on your income, your assets, and how much of the IRS’s 10-year collection window remains.
I represent California businesses in EDD audits, worker reclassification assessments, and California Unemployment Insurance Appeals Board proceedings.
Every Form 941-X is a separate claim to the federal government. DOJ is actively using the False Claims Act to pursue ERC fraud — including treble damages and civil penalties per return. Here is what employers need to understand.
Part of our comprehensive guide: The Ultimate Guide to Cannabis Industry Tax Pitfalls
Tax debt forgiveness is real, but it does not work the way TV ads promise. We explain the legitimate IRS programs that can reduce or eliminate your tax debt and which one fits your situation.
A CP2000 is a proposed change — not an audit and not a final bill. You have 60 days to respond. Here’s what it means and what to do about it.