The RegistryPractice Area · Statewide
Tax Attorneys in California
Counsel for the IRS and the FTB — audits, liens, and negotiated resolutions. This is the statewide record for tax in California — every attorney on the State Bar of California's official roll whose practice reaches this shelf, scored in the open by the published Growth Score.
Californians search this field under many names — tax attorney, tax lawyer, irs audit lawyer, irs tax attorney, tax debt attorney — and the registry answers all of them from the same source. Below: the governing deadline with its citation, what to weigh as you read the roster, the questions Californians ask with the code sections that answer them, and the record city by city, from the North Coast to the border.
The clock & the craft
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).
Reading the roster
Tax controversy is a paper-and-deadline practice: bring every notice, with dates, to a first consultation, because appeal windows (90 days for Tax Court, 60 for an FTB protest) drive everything. Look for attorneys who practice before the IRS, FTB, EDD, and CDTFA regularly, ask whether your matter is an audit defense, a collection resolution, or litigation, and confirm who — attorney, CPA, or enrolled agent — will handle each stage. Attorney-client privilege is a genuine differentiator when fraud exposure is possible.
Tax · statewide 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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Read the record. Then decide.
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