Services

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.

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 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.

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.

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.

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 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.

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.

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.

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.

We analyze every available resolution program, determine which one produces the best outcome for your financial situation, and handle the entire process from application through acceptance.

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.