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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.

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.

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.

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.

We represent California businesses in EDD audits, worker reclassification assessments, and California Unemployment Insurance Appeals Board proceedings.

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