WELCOME. I am San Diego tax attorney
Since 1984, I have successfully
assisted thousands of clients with resolving their
IRS and California tax disputes and I have saved them millions of dollars in taxes. My San Diego
law practice is limited to IRS and California civil tax and criminal tax disputes.
If you are involved in an IRS or California tax dispute, I can help you regardless of where you live. You don't need to fear the IRS with me on your side. Put my 30 years of tax law experience to work for you.
THE LEADING SAN DIEGO TAX DISPUTE ATTORNEY
If you are serious about resolving your tax dispute, I can help you. I have 30 years experience as a CA Tax Attorney in San Diego and top credentials. I have been selected by my peers as one of the best lawyers in America. I am Certified as a Tax Law Specialist by the State Bar of California. This is the highest designation available to a California tax attorney. I have been a Certified Tax Law Specialist for 25 years. I have also been named a "Super Lawyer" for nine consecutive years - in 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, and 2016. Also, Martindale-Hubbell has awarded me an "AV Preeminent" rating. This is the highest and most prestigious rating available to any U.S. attorney for legal skills and ethics.
TAX LAW PROFESSOR FOR 22 YEARS
For the past 22 years, I have also been a part-time tax law professor at the University of San Diego School of Law. I teach both the Criminal Tax Fraud class and the Tax Court Litigation class. I am the only attorney in San Diego who teaches the Criminal Tax Fraud class and the only attorney in San Diego who teaches the Tax Court Litigation class. I am also the author of 14 published tax law articles, including some of the leading articles in the U.S. in resolving civil and criminal tax disputes.
HOW I WILL RESOLVE YOUR TAX DISPUTE
To successfully resolve a tax dispute, requires skill. As your tax case has its own unique set of facts, I will never use a "one size fits all" solution approach - because that won't resolve your specific tax problem. I approach each case as unique. In fact, the strategy and approach that I used for my last client might be the wrong strategy for your specific case; as no two clients have the exact set of facts. After I understand all of the unique facts in your case, I will develop a specific defense strategy just for your case. In addition, I pay careful attention to details; because there is no such thing as a routine call or a routine meeting with the IRS. I will tailor each communication to the IRS on your case precisely to your specific tax defense plan. Each communication to the IRS means something and I will make sure that nothing is overlooked or taken for granted. Over the past 30 years, this attention-to-detail approach has benefited my clients greatly. You need me, a "Super Lawyer" with 30 years of Tax Law experience, working for you.
TYPES OF TAX CASES I ACCEPT
A. IRS TAX PROBLEMS
I help clients nationwide with the following IRS tax issues:
- IRS Tax Audit
- IRS Criminal Tax defense
- Tax Court Litigation
- IRS Offer In Compromise settlements
- Arrange IRS Installment Agreements
- IRS Appeals Division
- Trust Fund Penalty Defense
- Innocent Spouse Relief
- Foreign Bank Account Disclosure
- Defense of IRS tax preparer penalties
- Payroll Tax Audits/Collection Issues
B. CALIFORNIA TAX PROBLEMS
I also help clients nationwide with the following California tax issues:
- All Franchise Tax Board ("FTB") Issues
- FTB Tax Audit
- FTB "California residency" issues
- FTB Offer In Compromise Settlements
- All California Employment Development Department ("EDD") Tax Issues
- EDD Payroll Tax Audit/Collection Issues
- EDD Offer In Compromise Settlements
- All CA SBE (State Board of Equalization) Sales Tax issues
- CA SBE (State Board of Equalization) Sales Tax Audit
- California Criminal Tax representation
- Defense of California tax preparer penalties
DEDICATED TO HELPING TAXPAYERS FOR 30 YEARS
Unlike some tax controversy defense
attorneys, I did not start out my legal career as an IRS
attorney using the Tax Code against honest taxpayers. I also
did not start out my legal career as a federal prosecutor
working to put good people in prison for some mistakes on
their tax returns. Instead, I have devoted my entire 30 year legal career helping to defend hardworking
taxpayers against the far and powerful reaches of the Internal
Revenue Service and I am proud of that accomplishment. Being
an effective tax controversy attorney is a mindset
and I have had that tax defense mindset for my entire 30 year legal career.
RESULTS . . . that's the bottom line ... what every client is looking for.
During the past 30 years, I have helped thousands of clients resolve their tax disputes with the IRS and the State of California and have saved them millions of dollars in tax and penalties.
Here are just a couple of recent client results.
A) On January 21, 2016, the U.S. District Court in San Diego dismissed all criminal tax charges against my client. The Government had previously Indicted my client for structuring of bank deposits to avoid the bank financial reporting requirements.
B) In a recent 2015 Tax Court case, the IRS was seeking approximately $3,000,000 in additional tax, penalties and interest. I was able to obtain Innocent Spouse relief for my client…and therefore, she did not owe the IRS any money. That was a $3,000,000 reduction.
C) I was the lead attorney for the Petitioner in David Carreon v. Commissioner (T.C. Memo 2014-6). The IRS had asserted that my clients - the Petitioner, and his two related corporations - were subject to a 75% civil fraud penalty. After a trial in U.S. Tax Court, Judge Wherry issued his written Decision. The U.S. Tax Court ruled that my clients - were NOT subject to a civil fraud penalty. This was a COMPLETE VICTORY FOR MY CLIENTS.
Despite my strong record of favorable client outcomes during the past 30 years, I refrain from making any case result predictions to you about your case without knowing the complete facts of your case. Each tax case has its own unique set of facts. I urge you to call me today for a FREE consultation. You can also email me in confidence.
GUIDANCE YOU CAN TRUST
During the past 30 years, many San Diego attorneys, CPA's and other tax professionals have referred their own clients and family members to me for help in resolving their serious tax problems with the IRS and the state of California. These local tax professionals knew that I would do my best to produce the best results possible their clients and family members.
HELP IS AVAILABLE TO YOU NATIONWIDE
I understand how a tax problem can take hold of your life and affect your ability to sleep at night. If you are serious about resolving your IRS and/or CA tax problem, I can help you regardless of where you live. Call today to discuss your unique tax situation in complete confidence. You can also email me in confidence. Put my 30 years of tax law experience to work for you.
YOU DON'T NEED TO FEAR THE IRS WITH ME ON YOUR SIDE