Tax Controversy and Litigation

Advocate Solutions has successfully represented individuals and businesses in disputes with the Internal Revenue Service (IRS), Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), Employment Development Department (EDD), and California Unemployment Insurance Appeals Board (CUIAB). We also represent business owners in gross receipts audits by the Departments of Finance throughout various cities in California.

Some of the more specific tax litigation and controversy issues Advocate Solutions handles include:

• Audits
• Appeals
• U.S. Tax Court Litigation
• Tax Refund Claims and Abatements
• Tax Collection Defense
• Offer in Compromise
• Installment Agreement
• Collection Due Process (“CDP”) Hearings
• Collection Appeal (CAP) Requests
• Penalty Abatements
• Innocent Spouse Claims
• Injured Spouse Claims
• Wrongful Levy Actions
• Levies, Liens, Garnishments
• Bankruptcy Discharge of Taxes
• Trust Fund Recovery Penalty (Payroll and California Sales Tax)
• Worker Classification
• Wage and Hour Issues
• Unfiled Tax Returns
• IRS Voluntary Disclosures
• FBAR and 5471 Penalties
• Multi-State Tax Compliance
• California Tax Practice
• Sales and Use Taxes

Advocate Solutions’ civil tax litigation and controversy clients include individuals and small to mid-sized businesses. The substantive tax issues we address involve income, estate, property, business and payroll, sales, employment, payroll, and international tax issues. We also represent clients at all phases of a tax dispute, from audits to protests and administrative appeals, and from court litigation to collection resolution matters like offers in compromise and installment agreements. Our national expertise in bankruptcy, distinguish our collection defense practice firm from other tax controversy law firms.