California Tax Defense — Poway, San Diego County
Poway Tax Attorney
I represent clients from Poway from my office in San Diego. Poway has a real business base — technology, defense, manufacturing, professional services — and the tax disputes that come out of that landscape tend to be more complex than the average notice. R&D credits, officer compensation, business expense substantiation, and residency questions are all areas I deal with regularly. Brotman Law has handled over 2,500 tax matters. If something’s come up and you want a direct read on it, book a free 15-minute call.
Tax Issues That Show Up in the Poway Business Community
Poway’s mix of companies — defense contractors, tech firms, manufacturing — means the tax disputes I see from this area tend to involve the IRS scrutinizing business expenses, R&D credit claims, and owner compensation structures more heavily than in a purely residential community. These are technical cases. They require someone who understands both the law and the industry context.
On the individual side, high-income Poway residents frequently deal with FTB residency audits, underpayment penalties, and estate and gift tax questions. And any Poway business with employees has some exposure to EDD payroll tax audits, particularly if you use independent contractors in a labor-intensive workflow.
The common thread: these are legal disputes with the government, and the response strategy matters as much as the underlying facts. Learn more about Brotman Law’s San Diego-based tax practice.
IRS Audits and Collections — What We Handle
When the IRS proposes additional tax, it’s initiating a dispute over what you owe. A Form 4549 exam report is essentially a bill the government has written for itself — and you have the right to push back. The procedural steps matter: Information Document Requests (IDRs), 30-day letters, 90-day letters, and appeals all operate on strict timelines.
We handle:
- IRS field examinations — business and individual income tax
- Correspondence audits and CP2000 responses
- Research and development credit audits under IRC § 41
- Eggshell audits with potential criminal exposure
- IRS collections: liens, levies, wage garnishments
- Installment agreements, Offers in Compromise, and currently not collectible requests
- Collection Due Process (CDP) hearing representation
- Tax Court petitions and IRS Appeals representation
- Trust fund recovery penalty (TFRP) defense under IRC § 6672
If you’ve received a 90-day letter (Notice of Deficiency) and the deadline to file a Tax Court petition is approaching, call us now. That window doesn’t extend.
California State Tax: FTB, EDD, and CDTFA
California runs four separate tax agencies, and each has its own audit program. A business that catches the attention of one agency sometimes finds itself facing audits from multiple directions — FTB on income, EDD on payroll classification, CDTFA on sales tax — within the same fiscal year.
For Poway clients specifically, we handle:
- FTB income tax audits, desk audits, and field exams
- FTB protest hearings and Office of Tax Appeals (OTA) representation
- FTB residency audits — domicile analysis and the 546-day safe harbor
- EDD payroll tax audits and worker classification (AB5 / employee vs. contractor)
- CDTFA sales and use tax audits and petitions for redetermination
The FTB’s residency audit program has been active in recent years targeting high-earners who left California. If you left Poway and the FTB is claiming you remained a California resident, the defense requires documentation of your domicile change — it’s a specific set of facts, and it responds well to early preparation.
Criminal Tax Defense for Poway Clients
IRS Criminal Investigation (CI) handles federal criminal tax cases — tax evasion, false returns, unreported income. If a special agent has contacted you, or if you’ve received a grand jury subpoena, you should speak with a tax attorney before you speak with anyone else. Attorney-client privilege covers communications with your attorney. It does not cover communications with your accountant or financial advisor.
I hold an LL.M. in Taxation. Criminal tax cases require a different level of representation than civil audits, and the overlap between civil and criminal exposure is often not obvious until you have an attorney reviewing the full picture. Let’s talk about it before you respond to anything.
Getting Started from Poway
The first step is a 15-minute call — free, no commitment. I’ll listen to what you’re dealing with, tell you what I think it means, and give you a realistic picture of the options. If we’re a good fit, we’ll talk about next steps.
My office is at 12636 High Bluff Drive, Suite 300, San Diego, CA 92130 — about 20 minutes south of Poway. Phone: 619-378-3138. Most client work is handled remotely, so a trip isn’t required.