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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.

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.

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.

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.

Part of our comprehensive guide: The Complete Guide to California CDTFA Collections

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 IRS can ask the State Department to revoke or deny your passport if you owe more than $62,000 in assessed federal tax debt. Here’s what the law actually requires — and what to do about it.

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.

Part of our comprehensive guide: The Complete Guide to California CDTFA Collections