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Is Brotman Law Right for Me?
Brotman Law is the right firm when you have a real dispute with the IRS or a California tax agency, or a transaction big enough that the tax structure changes the outcome, and you want it handled by people who do this all day. It is the wrong firm for a lot of things people call about, and we would rather tell you that in the first 15 minutes than after an engagement letter. Here is the honest version of who we are for.
Sam Brotman, J.D., LL.M.
We are probably right for you if
- An agency has sent you something with a deadline. An IRS audit letter or CP2000, a revenue agent’s introduction, a CDTFA Notice of Determination, an EDD Notice of Assessment, an FTB Notice of Proposed Assessment, a Final Notice of Intent to Levy. Deadlines are where cases are won and lost, and most of them are 30 days.
- You own a business, or the problem comes from one. Contractors, restaurants, professional practices, e-commerce sellers, real estate investors, and the people who own them. Business tax problems are procedural and multi-agency, and that is our practice.
- The number is serious. Our engagements start at $3,500, and the fee only makes sense when the exposure is a multiple of it. As a rough rule, a proposed liability or assessment in the tens of thousands or more, penalties on top of it, or personal liability for a business tax.
- The facts could get worse. Unreported income, cash, records that are missing, a second set of books, an offshore account. When an audit has criminal exposure, you need privilege from the first response, and only a lawyer gives you that.
- You are about to do something large. Selling a company, buying a building, leaving California, forming an entity. Strategy is worth the most before the event, and the structuring work is a defined flat fee.
- You want a straight answer and a fixed price. We quote fees before you sign and most clients are on a monthly flat fee that pauses while the agency is doing its part. If you want to call your lawyer without watching a meter, that is the model.
We are probably not right for you if
- You need a tax return prepared. We prepare returns only inside a strategy engagement for clients with complex structures. For preparation and bookkeeping you want a CPA, and we are happy to refer one.
- The balance is small and you can pay it. If the IRS says you owe $4,000 and the numbers are right, set up the payment plan online and keep your money. A lawyer would cost more than the problem.
- It is a first notice and nothing is wrong. A CP14 or a CP501 is a bill, not an audit. Pay it or set up an installment agreement. Our notice library tells you which letters need a lawyer and which do not.
- You want a guarantee. Nobody can promise the outcome of a tax dispute, and any firm that promises to settle “for pennies on the dollar” before it has seen your financials is describing an Offer in Compromise you may not qualify for. We will tell you the realistic range. We will not tell you what you want to hear.
- You want to pay on contingency. Contingency fees are not standard in tax controversy, and for good reason: the strategy should be driven by your case, not by whether a payout is likely.
- The matter is outside tax law. Unemployment benefit claims and EDD benefit audits, property tax appeals, general business litigation, estate administration, immigration, and personal injury are not what we do. Tax law is the whole practice.
- You are looking for the cheapest option. There are national tax resolution companies that charge less and assign your file to whoever is available. Some people are well served by them. Our clients are the ones for whom the outcome matters more than the fee.
Things we tell callers to do themselves
In our practice, roughly a third of the people who call do not need us, and we tell them so. A CP2000 for a 1099 that was left off a return: answer it with the document. A balance under $50,000 you can pay within six years: the IRS streamlined installment agreement takes a few minutes online. A first-time failure-to-file penalty with a clean prior history: call the IRS and ask for first-time abatement. A routine EDD form on a properly classified W-2 employee: fill it in and mail it back. We would rather you keep the fee and remember who told you that.
What the first call is like
Fifteen minutes with our intake team, free, confidential, and without obligation. Have the letter in front of you. We will ask which agency, what the notice says, what stage it is at, and what the deadline is. You will leave the call knowing whether this is a matter that needs a lawyer, what representation would look like, and roughly what it would cost. If it is a fit, the next step is a strategy session with an attorney who reads the documents and gives you a plan and a number. Fees are on the pricing page.
What we handle, if it helps to check
- IRS audits, correspondence through field examinations and eggshell audits.
- IRS collections: liens, levies, installment agreements, Offers in Compromise, CDP hearings. The options are explained on tax debt resolution.
- CDTFA sales tax audits, petitions, and appeals.
- EDD payroll tax audits and worker classification.
- FTB income tax audits, residency, and collections.
- Criminal tax defense, federal and state.
- Tax strategy: entities, exits, residency, opinion letters.
Since December 2013 the firm has represented 400+ clients in audits, resolved 2,200+ matters, and eliminated more than $100 million in tax penalties and interest. If your situation looks like the first list, book the call. If it looks like the second, the notice library and the guides are free, and the number is the same if that changes.
Frequently asked questions
Do you take small cases?
Not usually, and not because they are beneath us. Our engagements start at $3,500, and a fee that size only makes sense when the exposure is a multiple of it. For small balances we will tell you how to handle it yourself on the free call.
Do you represent individuals or only businesses?
Both. Most of our clients are business owners, but we represent individuals in IRS and FTB audits, collections, residency disputes, international matters, and criminal tax cases.
Do I have to be in San Diego?
No. Federal matters are national, and California agency matters are handled by mail, phone, and video with hearings attended by counsel. We represent clients across California and, for IRS matters, across the country.
Will you tell me if I do not need a lawyer?
Yes, on the first call. That is what the call is for. A meaningful share of callers are told to handle it themselves, and we tell them how.
What should I have ready for the call?
The letter or notice, the tax years involved, and a rough idea of the amount. If an agent has already contacted you, the agent’s name and what was said. That is enough for us to tell you where you stand.
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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.