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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.

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.

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.

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.

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.