San Diego Tax Defense Attorneys for IRS, California & Federal Disputes

Written by Sam Brotman, J.D., LL.M., MBA
Updated April 15, 2026  ·  12 min read

When a Tax Problem Becomes a Tax Defense

Tax defense is the legal representation of businesses and individuals facing enforcement action by the IRS or a state tax agency. That enforcement can take the form of an audit, a collections action, a criminal investigation, or a combination of all three — and the strategy required to resolve each is fundamentally different.

The distinction between tax compliance and tax defense matters because the tools are different. A CPA files returns. A tax defense attorney intervenes when the government has already decided you owe more than you reported, you failed to file, or your conduct warrants criminal prosecution. The stakes are not just financial — they include personal liability, asset seizure, and in criminal cases, imprisonment.

Brotman Law is a San Diego tax law firm that represents clients exclusively in tax controversy and tax strategy matters. We do not prepare returns, sell financial products, or refer cases to other firms. Every attorney in our office works on tax disputes — IRS audits, criminal tax investigations, California state agency enforcement, and tax debt resolution. This page is the starting point for understanding what we do and how to find the right service for your situation.

Federal Tax Defense

Federal tax disputes involve the Internal Revenue Service and, when litigation is necessary, the U.S. Tax Court, Court of Federal Claims, or federal district court. The federal enforcement apparatus includes civil audit divisions, the IRS Office of Appeals, and for criminal matters, IRS Criminal Investigation (CI) and the Department of Justice Tax Division.

California Tax Defense

California operates three independent tax agencies — the Employment Development Department (EDD), Franchise Tax Board (FTB), and California Department of Tax and Fee Administration (CDTFA) — each with its own audit procedures, penalty structures, and appeal paths. A business operating in California can face enforcement from all three simultaneously, plus the IRS, creating compounding exposure that requires coordinated defense across every agency.

IRS Tax Debt Resolution

When the IRS assessment is final and the amount owed exceeds what you can pay in full, the question shifts from "how much do I owe" to "what's the best resolution path." The IRS offers several formal programs — but the right program depends on your financial situation, compliance history, and the type of tax debt. Choosing the wrong resolution path wastes time, triggers additional penalties, and can eliminate options that would have been available earlier.

Specialized Tax Defense

Some tax disputes require subject-matter expertise beyond general audit defense. Multi-state nexus issues, international reporting obligations, cryptocurrency transactions, cannabis industry compliance, and tax shelter investigations each involve distinct legal frameworks and enforcement patterns.

Sam Brotman

Owner & Managing Attorney · J.D., LL.M. Taxation, MBA

Sam founded Brotman Law in 2013 with a singular focus on tax controversy and tax strategy. He leads the firm's IRS audit defense and criminal tax practice, and personally oversees every client engagement from initial consultation through resolution.

Full Bio →