California Tax Defense — National City, San Diego County
National City Tax Attorney
I represent clients from National City from my office in San Diego. National City has a dense commercial district — auto dealerships, retail, food service, import/export, and a large working-class residential population — and the tax issues that come from those industries are specific and often serious. IRS collection actions, FTB income tax disputes, EDD payroll audits, CDTFA sales tax assessments. Brotman Law has handled over 2,500 tax matters. If you need a clear answer about what you’re dealing with, book a free 15-minute call.
Why National City Tax Cases Have Their Own Profile
National City’s economy is dominated by cash-intensive businesses, auto-related industries, retail and food service, and a large population of workers with multiple income sources. These characteristics show up in the types of tax disputes I see from the area: sales tax audits of auto dealers and retailers by the CDTFA, EDD audits of businesses using gig or contract labor, IRS collection actions from unreported cash income, and FTB disputes over California-source income from cross-border activity.
The legal issues in these cases are not complicated in theory — they’re complicated in execution. Getting the documentation right, responding to agency notices on time, and making the right legal arguments at each stage is where a tax attorney earns their fee. More about Brotman Law’s San Diego tax practice.
IRS Audits and Collections — What We Handle
The IRS has 10 years from assessment to collect a tax debt. That is the Collection Statute Expiration Date, or CSED. But in those 10 years, interest and failure-to-pay penalties compound, and the IRS’s collection tools — liens, levies, wage garnishments — are available throughout. The best time to deal with IRS debt is before the collection process runs its full course.
We handle:
- IRS field examinations and correspondence audits
- CP2000 automated underreporter responses
- Federal tax liens — notices of filing, subordination, discharge, and withdrawal
- IRS levies on bank accounts, wages, and receivables
- Collection Due Process (CDP) hearings
- Installment agreements and Offers in Compromise
- Currently not collectible (CNC) status
- Penalty abatement — first-time abatement and reasonable cause
- Trust fund recovery penalty (TFRP) under IRC § 6672
- Innocent spouse relief under IRC § 6015
- Tax Court petitions and IRS Appeals
If the IRS has filed a substituted-for-return (SFR) under IRC § 6020(b) — meaning it filed a return for you based on third-party information — that assessment may be higher than your actual liability. That can be challenged, but the process and timeline depend on where in the collection sequence the account sits. Let’s look at the transcripts together.
FTB, EDD, and CDTFA — California State Tax Defense
National City businesses interact with multiple California tax agencies simultaneously. The CDTFA is a particular presence in any retail or auto-related business — sales tax audits in this sector are detailed, technical, and often result in significant proposed assessments.
We represent National City clients in:
- CDTFA sales and use tax audits, including auto dealer audits
- CDTFA petitions for redetermination and Office of Tax Appeals (OTA) representation
- FTB income tax audits and protest hearings
- FTB collections — liens, levies, and installment arrangements
- EDD payroll tax audits and worker classification disputes
CDTFA audits of auto dealerships can be complex — the agency scrutinizes documentation of exempt sales, dealer trades, service contracts, and cash transactions. If you’ve received a CDTFA audit notice, having an attorney coordinate the response from the beginning generally leads to better outcomes than handing it to a CPA and escalating to legal help after the proposed assessment issues.
Criminal Tax Defense
Criminal tax investigations are handled by IRS Criminal Investigation — a separate, specialized division. If a special agent has contacted you, or if you’re aware that you have exposure related to unreported income, offshore accounts, or other serious matters, the time to speak with an attorney is before you speak with the government. Attorney-client privilege protects communications with your lawyer. It does not protect communications with your accountant.
I hold an LL.M. in Taxation. Call me before responding to any CI contact.
Getting Started from National City
The first call is 15 minutes, free, no commitment. We’ll talk through your situation, I’ll tell you what I think it means and what the options look like. My office is at 12636 High Bluff Drive, Suite 300, San Diego, CA 92130 — about 10 minutes from National City. Phone: 619-378-3138. Most client work is handled remotely.