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Tax Attorneys in Merced County, California
Counsel for the IRS and the FTB — audits, liens, and negotiated resolutions. In Merced County, that work runs through the Superior Court of California, County of Merced. This directory presents tax records from official State Bar of California data in neutral order.
A San Joaquin Valley county where dairy and row-crop agriculture anchor the economy and UC Merced, opened in 2005, is the University of California's newest campus; the courthouse sits in the city of Merced. Venue for most tax matters arising in the county lies with the Superior Court of California, County of Merced, seated at Merced.
Before comparing counsel, note the clock. Under 26 U.S.C. § 6501, the governing period is the IRS generally has three years from filing to assess additional tax; the FTB has four (Cal. Rev. & Tax. Code § 19057). Substantial omissions double the federal window to six years (26 U.S.C. § 6501(e)); no return or fraud means no limit. A Tax Court petition must follow a notice of deficiency within 90 days (26 U.S.C. § 6213).
The clock & the court
The IRS generally has three years from filing to assess additional tax; the FTB has four (Cal. Rev. & Tax. Code § 19057).
26 U.S.C. § 6501
Substantial omissions double the federal window to six years (26 U.S.C. § 6501(e)); no return or fraud means no limit. A Tax Court petition must follow a notice of deficiency within 90 days (26 U.S.C. § 6213).
Superior Court of California, County of Merced.
County seat: Merced
Official court information, locations, and filing rules: www.merced.courts.ca.gov
Tax · Merced County roster
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Tax questions, cited
How far back can the IRS or the California FTB audit me?
The IRS generally has three years from the return's filing to assess more tax (26 U.S.C. § 6501), extended to six years when income is understated by more than 25% (§ 6501(e)) and unlimited for fraud or unfiled returns. The California Franchise Tax Board has four years (Cal. Rev. & Tax. Code § 19057) — and California has no collection-barring statute comparable to the IRS's ten-year rule until 20 years after assessment (§ 19255).
What can I do if I cannot pay my tax debt?
Both agencies offer structured resolutions: installment agreements (26 U.S.C. § 6159), offers in compromise settling the debt for less than owed where collection potential is limited (26 U.S.C. § 7122; FTB equivalent under Rev. & Tax. Code § 19443), and currently-not-collectible status. Penalty abatement for reasonable cause is separately available. Ignoring notices forfeits appeal rights that are often the real leverage.
What is the deadline to challenge an IRS notice of deficiency?
Ninety days from the notice date to petition the U.S. Tax Court (26 U.S.C. § 6213) — the only forum where you can litigate before paying. Miss it, and the tax is assessed; challenge then requires paying first and suing for a refund (26 U.S.C. § 7422). California FTB deficiency protests run 60 days (Rev. & Tax. Code § 19041), with appeals to the Office of Tax Appeals.
Am I responsible for my spouse's tax debt?
Joint filers are jointly and severally liable (26 U.S.C. § 6013(d)(3)), but innocent spouse relief under 26 U.S.C. § 6015 can relieve a spouse who did not know of understatements and for whom liability would be inequitable; California mirrors this in Rev. & Tax. Code § 18533. Community property rules complicate separate filings in California, which is one reason these cases benefit from counsel.
When does unpaid payroll tax become personal liability?
When the business fails to remit withheld taxes, the IRS can assess the trust fund recovery penalty — 100% of the unremitted amount — personally against any "responsible person" who willfully failed to pay (26 U.S.C. § 6672). California's EDD imposes similar personal liability (Cal. Unemp. Ins. Code § 1735). Owners, officers, and even bookkeepers with check-signing authority can be reached.
Legal information, not legal advice.
From the answer files
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