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IRS Payment Plan

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.
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IRS Wage Garnishment

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.
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FTB Audit

The Franchise Tax Board audits California income tax returns independently of the IRS — with a 4-year statute of limitations, a 60-day protest window, and automatic triggers when the IRS changes your federal return.
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IRS Information Document Request (IDR)

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.
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IRS Collections Attorney

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.
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The 4 Types of IRS Audits

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.
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1031 Exchange Attorney

Deferring capital gains on California investment property — and handling the mechanics, the QI, and the FTB clawback trap the right way.
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The EDD Pre-Audit Questionnaire

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.
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IRS Criminal Investigation

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.
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Tax Avoidance vs. Tax Evasion

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.
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San Diego Offer in Compromise Attorney

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.
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San Diego Tax Court Lawyer

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.
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California EDD Audit Penalties

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.
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ERC Litigation Attorney

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.
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Tax Evasion Jail Time, Penalties

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.
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IRS Tax Debt Relief

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.
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EDD Audit Attorney

I represent California businesses in EDD audits, worker reclassification assessments, and California Unemployment Insurance Appeals Board proceedings.
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ERC Audit Defense

The ERC filing deadline has passed. The IRS audit program has not.
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ERC and the False Claims Act

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.
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IRS Audit Issues for Cannabis Businesses

Part of our comprehensive guide: The Ultimate Guide to Cannabis Industry Tax Pitfalls
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California Audit Issues for Cannabis

Part of our comprehensive guide: The Ultimate Guide to Cannabis Industry Tax Pitfalls
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ERC Statute of Limitations

The One Big Beautiful Bill Act extended the IRS examination window for ERC claims. Here’s what the new ERC audit window means for open claims — and what to do if you receive an audit notice.
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Tax Debt Forgiveness

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.
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IRS Statute of Limitations

The IRS does not have forever to audit you or collect your tax debt. Understanding these time limits is one of the most powerful tools in tax defense.
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IRS CP2000 Notice

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.
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IRS Audit Triggers

The IRS audits less than 1% of returns, but certain factors dramatically increase your odds. Know what triggers scrutiny so you can file with confidence.
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Can You Go to Jail for Not Paying Taxes? A Tax Attorney Explains

Can You Go to Jail for Not Paying Taxes? A San Diego Tax Attorney Explains By Sam Brotman, J.D., LL.M. […]

The Settlement Advantage: How ERC Litigation Brings Finality and Protection

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

ERC Refunds and PEOs: Who’s Really Responsible?

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

ERC Refunds: The Fork in the Road – Administrative Path vs. Litigation

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

The Three Elements of a Powerful Tax Strategy

To know if tax debt relief companies are genuine or legitimate. Brotman Law has given all the information you need.

Why a Corporate Holding Company Could Be Your Smartest Tax Move Yet

To know if tax debt relief companies are genuine or legitimate. Brotman Law has given all the information you need.

Tax Compliance vs. Tax Strategy: Why It Pays to Know the Difference

To know if tax debt relief companies are genuine or legitimate. Brotman Law has given all the information you need.

Is Your CPA Holding You Back from Real Tax Savings?

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.
Close-up of a calendar with the word 'Tax' circled in red ink, marked with a pin, symbolizing a critical tax deadline or planning date.

The Hidden Cost of Doing Nothing: Why You Might Be Overpaying the IRS

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

ERC Refund Processing Time: How Long Will It Take — and What Can You Do About It?

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

Used a Third-Party ERC Provider on Contingency? Here’s What You Should Know Before You Pursue a Refund Claim

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

Do You Qualify for the Employee Retention Credit? How to Evaluate Your ERC Claim Before Filing a Lawsuit

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

ERC Litigation and PEOs: How to Protect Your Refund and Hold Your Provider Accountable

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

Can the IRS Claw Back My ERC Refund? Why Litigation May Be Your Best Defense in 2025

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.
Man handing over a check for ERC refund process 2025.

ERC Refund Update 2025: How To Expedite Your ERC Refund

Is your ERC refund delayed? Discover how filing a lawsuit against the IRS can expedite your claim, force a resolution, and potentially lead to a settlement. Learn how litigation could help you recover your refund faster.

ERC Refund Lawsuits: What Happens When You Sue the IRS?

Is the IRS delaying your Employee Retention Tax Credit refund? Learn why businesses are suing the IRS for ERC refunds, the legal process, and how litigation could be your best option to recover your refund faster.
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