Federal and California tax disputes, offshore disclosure and international tax.

IRS Audits & Appeals

Audits · Independent Office of Appeals · Collection Due Process

Common situations

• You received an audit letter, an Information Document Request, or a 30-day letter proposing additional tax.
• You disagree with an auditor's findings or a proposed penalty, and want an independent review.
• You received a notice of intent to levy or a notice of federal tax lien filing, and the deadline to request a Collection Due Process (CDP) hearing is running.

How I help

• Manage the audit: document requests, interviews and the auditor relationship, with a Form 2848 on file so the IRS deals with me.
• Write the protest and represent you at the Appeals conference — the same process I worked in as an Appeals Officer.
• Request and handle CDP hearings before Appeals.

California Tax Disputes & Audits

EDD · FTB · CDTFA

EDD payroll tax audits

• The EDD is auditing your payroll tax reporting — unemployment insurance, employment training tax, state disability insurance and California income tax withholding — and proposing an assessment.
• I review the auditor's findings and wage computations, respond to the audit, and file petitions to challenge the assessment.

EDD worker classification

• The EDD is auditing your business — often after a worker files an unemployment claim — and is applying California's ABC test to treat your independent contractors as employees.
• I analyze each worker relationship and the available exceptions, including the business-to-business exception, respond to the audit, and file petitions to challenge the assessment.

Franchise Tax Board (FTB)

• Residency audits, income tax audits and notices of proposed assessment.
• Protests to the FTB and appeals to the Office of Tax Appeals.

California residency planning

• Moving out of California, or splitting time between states? I help you plan the move and keep the records that show where you are domiciled, so you are prepared if the FTB asks.

Sales and use tax (CDTFA)

• Representation in CDTFA audits and appeals, and arrangements for post-audit balances.

Offshore Disclosure & FBAR

FinCEN 114 · Forms 14653, 14654, 8938

Common situations

• You learned you should have filed FBARs for foreign bank, brokerage or retirement accounts, and you want to get compliant.
• You received an IRS letter proposing non-willful or willful FBAR penalties.
• You are deciding between the Streamlined procedures, delinquent FBAR submission, or another path.

How I help

• Assess willfulness exposure and recommend the right compliance path.
• Prepare Streamlined Domestic (Form 14654) and Streamlined Foreign (Form 14653) submissions, including the non-willful narrative statement, amended returns and FBARs.
• Represent you in FBAR penalty audits and before IRS Appeals.

Related: FBAR penalty cases — what the courts have decided, and the facts behind willfulness

International Tax

Disputes & compliance · Foreign tax credits · CFC / Subpart F · GILTI · FDII · BEAT · Forms 5471, 5472, 8621, 3520, 3520-A

Common situations

• The IRS is auditing your cross-border positions — foreign tax credits, CFC income under Subpart F or GILTI (now "net CFC tested income"), FDII (now "foreign-derived deduction eligible income"), or the base erosion tax (BEAT) — and proposing adjustments.
• You own part of a foreign company, received a large gift or inheritance from abroad, or hold foreign mutual funds, and did not know a form was required.
• The IRS assessed a penalty for a late or missing international information return. These penalties often start at $10,000 per form, even when no tax is owed.

How I help

• Represent businesses and individuals in IRS audits and before Appeals on international issues, drawing on my years in KPMG's International Tax group and in the IRS Appeals international group.
• Prepare late or corrected filings for controlled foreign corporations (CFC), passive foreign investment companies (PFIC), foreign trusts and foreign gifts.
• Request penalty abatement based on reasonable cause, and appeal denials.

Trust Fund Recovery Penalty

IRC § 6672 · Letter 1153 · Form 4180 interviews · Appeals

Common situations

• A business fell behind on payroll taxes, and an IRS revenue officer wants to interview you as an owner, officer, bookkeeper or other signer on the account.
• You received Letter 1153 proposing the Trust Fund Recovery Penalty against you personally — the unpaid withheld taxes, assessed against you as an individual. The deadline to protest is generally 60 days from the date of the letter.

How I help

• Prepare you for the Form 4180 interview and attend it with you.
• Challenge whether you were a "responsible person" and whether any failure to pay was "willful" — the two elements the IRS must establish.
• Check the computation, including whether it is limited to the trust fund portion of the taxes and whether payments were properly applied.
• File a timely protest and represent you before the IRS Independent Office of Appeals, where I resolved TFRP cases as an Appeals Officer.

Related: The TFRP circuit by circuit — where the federal courts of appeals differ

Related: Case note — Crawford v. Commissioner (2026), on what happens when Letter 1153 goes unanswered

Information Return Penalties

IRC §§ 6721, 6722, 6724

Common situations

• Your business received an IRS notice proposing penalties for late, missing or incorrect information returns (§ 6721).
• The IRS is also proposing penalties for payee statements that were not furnished correctly or on time (§ 6722).
• The penalty was caused by a software, vendor or e-filing problem, or by a payee's incorrect taxpayer identification number.

How I help

• Review the notice and the filing history to find errors in the IRS's computation.
• Request a reasonable-cause waiver under § 6724 and document the facts that support it.
• Appeal denials to the IRS Independent Office of Appeals.

Form 8300 & Cash-Intensive Businesses

IRC § 6050I · Form 8300 audits · Businesses that routinely receive cash

Common situations

• Your business routinely receives cash payments as a normal part of how it operates, and the IRS has opened a Form 8300 compliance audit.
• The auditor is reviewing cash logs, deposits and customer files to see whether every cash receipt over $10,000 (in one transaction or related transactions) was reported within 15 days.
• The IRS is proposing penalties for missing, late or incomplete Forms 8300, or alleging "intentional disregard," which carries much larger penalties.

How I help

• Prepare you and your staff for the audit, manage document requests and interviews, and keep the auditor focused on the period and issues actually under review.
• Challenge the penalty computation and intentional-disregard findings, request reasonable-cause relief, and appeal to the IRS Independent Office of Appeals.
• Review your cash-handling, recordkeeping and reporting procedures so future filings are complete and on time.

Foreign Owners of U.S. Real Estate

Forms 8288, 8288-A, 8288-B

Common situations

• You are a foreign person selling U.S. property, and the buyer must withhold under FIRPTA — generally 15% of the sales price, not the gain.
• Withholding exceeds the tax you actually owe, and you want it reduced or refunded.

How I help

• Apply for a withholding certificate (Form 8288-B) to reduce withholding before closing.
• Handle the withholding returns and the nonresident tax return needed to claim a refund.
• Draw on my California real estate license to coordinate with escrow and agents.