Brotman Law handles complex tax disputes — the kind where the IRS is questioning your business structure, where there is real criminal exposure, or where multiple agencies are involved at once. For simpler matters, a CPA or enrolled agent is often the more practical choice. This page explains the difference.
The cases we are built for
We represent businesses, business owners, and high-net-worth individuals in tax disputes that go beyond what a CPA can manage alone. The common thread: something is genuinely at stake, and the facts are genuinely complicated.
You are probably a fit if:
- The IRS, DOJ, or a state agency (California FTB, CDTFA) has opened a civil or criminal examination of your business or personal returns
- There is more than $25,000 at issue — in tax, penalties, or interest
- You have received a notice that your case has been assigned to an IRS Revenue Agent (not just a correspondence letter)
- You are dealing with payroll tax debt, trust fund recovery penalties, or an eggshell audit where both civil and criminal exposure exist
- The IRS is questioning the structure of your transactions — not just a math error
- You need a formal Offer in Compromise, not just a payment plan
- You are a California business owner facing an FTB residency or domicile audit
- Your situation involves international elements — unreported foreign accounts, FBAR penalties, Form 5471 or 3520 issues
- You received ERC funds and are now being audited or contacted about those claims
- You are a high-income earner whose complex return has been assigned to a Revenue Agent for examination
The cases where we are probably not the right fit
We turn cases away when we are not the right tool for the job. That is not a marketing tactic — it is just how we run the practice.
We are probably not the right fit if:
- You received a CP2000 or similar notice about a simple discrepancy — a CPA or enrolled agent can usually resolve this for a fraction of what legal representation costs
- You have unfiled returns but no open audit and no criminal exposure — this is a compliance issue, not a legal dispute
- Your total tax debt is under $10,000 with clean facts — the IRS has standard installment agreements for this
- You need bookkeeping, tax preparation, or financial planning services — that is not what we do
- You need the least expensive option available — complex legal defense is not cheap, and we will not tell you otherwise
This is not false modesty. It is the honest answer to a question a lot of people do not ask directly.
A more honest answer to the overkill question
Maybe. That depends on what you are actually dealing with.
The short answer is: if your issue is procedural and the facts are straightforward, you probably do not need a tax attorney. A good CPA or enrolled agent can handle IRS correspondence audits, respond to CP notices, and help you get into an installment agreement. These are real skills. They are just not what we do.
What we do is represent people when the IRS or the DOJ has decided they want something your accounting team cannot fight. We have represented 2,500+ clients in matters ranging from criminal tax investigations to multi-year FTB residency disputes to international FBAR cases. The clients who are right for us are the ones who cannot afford a wrong answer — whether that is because the stakes are high financially, personally, or both.
If you are genuinely uncertain, the most useful thing we can do is spend 15 minutes talking through your situation and tell you honestly whether you need us. If you do not, we will say so.
What to do if you are not sure
If you are unsure whether your situation clears the threshold, here is a practical test:
- Has the IRS assigned a specific Revenue Agent to your case?
- Is there more than $25,000 at issue?
- Does the dispute involve your business structure, not just a single transaction?
- Is there any possibility of criminal referral?
If the answer to any of these is yes, it is worth a conversation. If all four are no, a CPA may be the better first call — and we are happy to point you in the right direction.
Frequently asked questions
How complex does my case need to be for Brotman Law to make sense?
There is no single threshold, but a useful benchmark is $25,000 or more at issue with an IRS Revenue Agent assigned to your case. Below that, the cost of specialized legal representation often outweighs the benefit. Above that — particularly when business transactions or multi-year audits are involved — the risk of getting it wrong is high enough that legal representation pays for itself.
Do I need a tax attorney or a CPA?
A CPA is the right call for tax preparation, compliance, and simple IRS notices. A tax attorney is the right call when there is a legal dispute — when the IRS is challenging your position on a legal question, when criminal exposure exists, or when you need attorney-client privilege to protect your communications. The practical test: if you would want the conversation to be privileged, call a tax attorney.
Is there a minimum dollar amount for cases Brotman Law takes?
We do not have a posted floor, but as a practical matter the cases we are best suited for involve at least $25,000 at issue. Below that threshold, the economics rarely favor full legal representation when other options exist.
What if I am not sure how complicated my situation is?
Book a free 15-minute call. We will tell you honestly whether your situation warrants legal representation, whether a CPA is the better fit, or whether it is somewhere in between. We would rather spend 15 minutes helping you find the right answer than have you hire us when we are not the right tool for the job.