Tax Law

Federal & State of CA tax planning, audits, federal collection due process hearings (CDPs), collection appeals program (CAP), appeals before the IRS Office of Appeals, penalty disputes, innocent spouse, tax liens, subordination, lien releases & discharge; wage & bank levies, asset seizure, collections (payment plans & offer in compromises), penalty abatements, IRA & retirement account penalties
Tax fraud & criminal tax investigations, representation & consultation
Attorney/client privilege representation & consultation
Fifth Amendment representation
U.S. Tax Court, District Court & U.S. Court of Federal Claims litigation
Federal tax opinions, taxation of legal settlements, capital gains analysis, 1031 exchanges
International tax: IRS voluntary disclosure, streamlined procedure, FBARs & foreign assets, income & property, foreign corp., partnership & gifts
Gift and estate tax planning
CA tax residency opinions
CA local tax matters-property tax, re-assessments, family property transfers under CA's Prop. 19, Prop. 13 property tax appeals based on change of ownership or new construction & Prop. 8 decline in value appeals