Los Angeles Tax Litigation Attorney

Awards & Recognition

When it comes to tax litigation disputes in Los Angeles, taxpayers may find themselves facing complex and challenging legal issues. Tax litigation can involve both civil and latent criminal tax matters, which may be heard in the following federal courts; U.S. Tax Court, U.S. District Court, and U.S. Bankruptcy Court. In addition to the federal courts, state courts in Los Angeles also hear tax litigation cases. These include the California Superior Court and the California Court of Appeals.

Tax disputes arise when an auditing agency believes that tax is owed while the taxpayer or a company may feel otherwise. Conflicts can also occur when taxpayers think they are entitled to a refund and the taxing authorities disagree. These disputes can be incredibly stressful and time-consuming, often requiring specialized knowledge and expertise in tax law and litigation. As such, it is essential to have an experienced dual licesned Tax Litigation Attorney & CPA in Los Angeles on your side to help navigate the complexities of these disputes and protect your rights throughout the tax litigation process. With the help of an experienced Los Angeles tax litigation attorney, taxpayers can achieve the best possible outcome in their tax disputes and minimize the negative impact on their finances and reputation.

At the Tax Law Offices of David W. Klassing, we understand the complexities of tax law and litigation, especially when civil tax fraud or criminal tax charges are a possiblity. We offer the guidance of experienced criminal tax defense attorneys to help clients respond appropriately to potential criminal tax charges or understand their legal standing before entering a civil tax audit. With our help, clients can better prepare themselves and ensure they are fully equipped to navigate the complexities of tax litigation. Being proactive and well-prepared in tax litigation matters is crucial. We work closely with our clients to develop tailored legal strategies considering their unique circumstances and goals. With our deep understanding of tax laws, auditing procedures, and extensive experience in tax litigation & appeals, we can provide clients with the tools and knowledge they need to achieve an optimal outcome. 

If we do not believe your circumstances will be improved via litigating, we will advise you so from the outset of your case. To prevail the law and facts must be on your side. We excel at making this determination.

We have extensive experience in helping clients respond strategically to exposure surrounding IRS audits, offshore tax investment, or allegations surrounding false income tax returns. By working with the Tax Law Offices of David W. Klassing, clients can better understand the intricacies of tax law and litigation and be better equipped to navigate the process. We pride ourselves on our commitment to honesty and integrity, and we never put our needs to make a living above our clients’ needs to be treated fairly by the taxing authorities. With an excellent track record of success and our commitment to only taking cases where we believe we can achieve a positive outcome, clients can rest assured that they are in good hands.

Navigating Tax Disputes: Understanding the Tax Litigation Process

Tax litigation is a complex process for taxpayers when the IRS or state tax authorities are attepting to legally asses additional tax, penalties & interest. This commonly occurs due to an audit, where the IRS or state tax authorities propose changes to one or more tax returns. In Los Angeles, taxpayers have the right to appeal the proposed changes within 30 days of receiving an examination report outlining the proposed changes. Or within 90 days of receiving a federal notice of determination (90 day letter).

At this stage, taxpayers have two options: accept the proposed changes or file a tax court petition if they believe the IRS has made an error in law or fact. Filing a tax court petition involves challenging the proposed changes in court, which can be lengthy and complicated. If taxpayers choose to appeal, they will typically conference with an IRS Appeals Officer and file a formal written protest outlining their disagreements with the proposed changes. If an agreement cannot be reached, taxpayers may receive a notice of deficiency, which provides 90 days to file a petition with the U.S. Tax Court. It is important to note that if taxpayers do not respond to the 30-day or 90-day letter, the proposed changes will be assessed regardless of whether they were made in error.

Navigating the tax litigation process can be challenging, which is why it is crucial to work with an experienced tax litigation attorney. If the IRS has made an error in the law or the facts, taxpayers can file a tax court petition to challenge the proposed changes. In these cases, the Tax Law Offices of David W. Klassing can help clients develop a legal strategy to prove that the law and the facts are on thier side. Our extensive experience in tax litigation appeals and deep understanding of tax law and procedure enable us to assess the strengths and weaknesses of our client’s cases and increase their chances of success.

If we can prove that the IRS has erred in either the law or the facts, we often have a 90% chance of bettering our clients’ situations, which means we can potentially reduce their tax penalties and interest by a substantial margin. In nearly every case we have litigated to date, the reduction in tax penalties and interests and has substantially exceeded the cost of litigation, making it a extrodinarily worthwhile investment for our clients. By working with us, clients can gain peace of mind from knowing they have a skilled legal advocate on their side who is dedicated to achieving the best possible outcome for their case.

By developing strong legal strategies, excelling at provinging compelling evidence and zealously advocating for our clients, we have settled everu case to date without the expense of actual tax court litigation. Litigation is a complex and often costly process. We understand the importance of cost-effective solutions for our clients. To date, we have successfully avoided taking our clients to tax court, which can be one of the most expensive parts of the tax litigation process. By utilizing our extensive knowledge and experience in tax law, we have strategically navigated the tax litigation process to find alternative solutions that work in the best interests of our clients. This approach has allowed us to achieve favorable outcomes for our clients while minimizing the financial burden associated with tax litigation. To set up a reduced-rate initial consultation with the best Los Angeles tax litigation attorney, call us at (949) 681-3502 or (800) 681-1295, or contact us online today.

Expert Tax Litigation Services for Complex Tax Disputes

Our skilled tax litigation lawyers have extensive knowledge and experience dealing with various federal and state tax issues. This incorporates representing clients in cases involving IRS audits, disputes with the CDTFA, EDD, BOE, and FTB, claims for refund, tax collection defense, innocent spouse relief, criminal tax defense, and more. With our in-depth understanding of tax law and procedure, we are dedicated to providing comprehensive legal support to our clients, protecting their rights and interests at every stage of the tax litigation process. Our services include representing the client in the following:

IRS Disputes: When dealing with the IRS, taxpayers may face a range of disputes, such as audits, deficiency notices, or refund claims. These situations can be stressful and complicated, requiring specialized knowledge and expertise in tax law and procedure. Hence, it’s essential to have a skilled legal advocate who can vigorously advocate for your interests before the IRS. We have extensive experience in representing clients in IRS disputes, helping them navigate the complex nature of the process, and ensuring that their rights are protected throughout the litigation period.

The California Department of Tax and Fee Administration (CDTFA): This agency collects taxes and fees that support various state programs, such as public health, transportation, schools, and natural resources management. Some of the taxes that the CDTFA collects include sales and use taxes, including fuel taxes, tobacco taxes, alcohol taxes, and cannabis taxes. If you are facing any issues with the CDTFA, such as an audit or dispute, our team at the Tax Law Offices of David W. Klasing can be your advocate and guide you through the process. We have extensive experience handling CDTFA matters and can help protect your rights and interests during these complex legal proceedings.

The California Employment Development Department (EDD): EDD administers the state’s payroll tax program and is responsible for enforcing employment tax laws. As an employer, it is crucial to comply with all employment tax laws to avoid penalties and legal repercussions. We can assist clients with EDD audits, appeals, and litigation, helping them navigate employment tax laws’ complex and ever-changing landscape. Our team of experienced attorneys can work to protect the rights of our clients and ensure that they receive a fair outcome in their EDD disputes.

The California Board of Equalization (BOE): BOE is responsible for administering various taxes and fees in California, including sales tax, property tax, and special taxes. They also oversee appeals for other state taxes and fees. If you face issues with the BOE, such as disputes over tax liability, we can provide skilled legal representation to protect your rights and advocate for your interests. Our experienced EDD tax attorneys can guide you through the complex BOE appeals process and work to achieve the best possible outcome for your case.

California’s Franchise Tax Board (FTB): This agency collects personal and corporate income tax in California. We have a strong track record of representing businesses and individuals before the FTB, helping them navigate complex tax laws and regulations while advocating for their interests.

How a Los Angeles Tax Litigation Attorney Can Help You

It’s important to note that the IRS has a 98% settlement rate and often prefers to settle rather than litigate. Working with an experienced & successful tax litigation attorney dramatically increases your chances of reaching a favorable settlement and avoid costly and time-consuming courtroom litigation. At the Tax Law Offices of David W. Klasing, we are committed to providing our clients with the highest level of legal representation and advocacy. We will tirelessly protect your rights and interests throughout the tax litigation process.

However, if push comes to shove and we need to start the litigation process, we will begin by thoroughly reviewing your case. This involves gathering all relevant information and documents, analyzing the details of the dispute, and identifying any potential legal issues. We will also review your past tax returns, financial records, and any correspondence with the IRS or state tax authorities to gain a clear understanding of the situation. By taking a comprehensive approach to reviewing your case, we can develop a solid legal strategy tailored to your unique needs and goals.

As experienced tax litigation attorneys, we will navigate an IRS or state tax audit, which can be overwhelming and complex. We will review any notices of deficiency received and address them promptly and strategically. In addition to guiding clients through the audit process, we also thoroughly explore the merits and strengths of their cases. We will carefully examine all the facts and applicable tax laws and evaluate the likelihood of success in contesting a deficiency, pursuing a refund, or addressing any other tax dispute issue. By assessing the strengths and weaknesses of each case, we can develop a comprehensive legal strategy to achieve the best possible outcome for our clients.

As part of the claim process, our tax litigation attorneys can ensure that all necessary steps are taken to properly file your claims, protecting your rights and avoiding additional penalties. We can review and analyze the details of your case to determine the best course of action and assist you in submitting the necessary documentation and evidence to support your claim. Additionally, we can explore alternative dispute resolution options such as mediation or arbitration to help you avoid the time and expense of tax litigation. Our attorneys have extensive experience negotiating with tax authorities, and we can work to reach a settlement in your best interest. We understand the importance of adequately navigating the claims process, as it can significantly impact the outcome of your case. Working with a skilled tax litigation attorney ensures that your claims are properly filed, and your rights are protected throughout the process.

We also provide representation for our clients in court or before administrative agencies, which includes preparing and filing legal briefs, presenting evidence, and advocating for our client’s rights and interests. Our attorneys have extensive experience in tax litigation and a deep understanding of tax law and procedure, allowing us to represent our clients in various tax disputes effectively. At the Tax Law Offices of David W. Klasing, we take a personalized approach to tax litigation cases. We understand that each client is unique and requires a tailored legal strategy. Our experienced tax litigation attorneys thoroughly understand and analyze your cases to identify potential strengths, weaknesses, and possible outcomes to develop a legal plan tailored to your needs and goals. today. To speak to tax lawyers who are experienced and thoroughly versed in IRS, California FTB, and California BOE audit and criminal investigation techniques and appeal processes, call 800-681-1295 or contact us online today to schedule a reduced-rate consultation.

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More Commonly Asked Tax Audit Questions

• How should Tax Audits be Handled by Criminal Tax Counsel?
• How to survive audit when I cheated on return being audited
• What is an eggshell audit?
• What is a reverse egg shell audit?
• Why is a reverse egg shell audit dangerous for a taxpayer?
• Warning signs of a criminal referral from an IRS audit
• Effective tax defense counsels goals in an egg shell audit?
• How are the 4 goals and outcomes 1 and 2 best obtained?
• What are the possible outcomes of an egg shell audit?
• Is it my right to know why I was selected for examination?
• What can I do to prepare for an audit?
• What is an IRS civil examination?
• How IRS decides which tax returns are audited
• What are my appeal options if I disagree with IRS?
• What are my basic taxpayer rights if the IRS audits me?
• Options if I am unable to pay at the conclusion of audit
• What a 30 or 90-Day Letter from the IRS means
• What is involved with appealing disagreements?
• Rights to disagree with IRStaxauditor’sss findings
• Can I stop the IRS from repeatedly auditing me?
• Can I have the examination transferred to another area?
• Can I record my IRS interview and is it a good idea?
• How many years of returns are at risk during an audit?
• Common reasons for the IRS to conduct a tax audit
• How to avoid negative consequences from an IRS interview
• Have to agree to interview by taxing authority directly?
• Are all audits the same?
• What should I do if the IRS is investigating me?
• What ifIdon’ttt respond to a taxing authority audit notice
• Your rights during an IRS tax audit
• Risks of attending an IRS audit without a tax lawyer
• Most common audit technique used by taxing authorities
• Don’t go into an IRS audit without representation
• Why hire an attorney to represent me in an audit?
• Why hire David W. Klasing to represent me in an audit

California Sales Tax Questions and Answers

• Common issues encountered during sales tax audit
• What is a sales tax audit?
• Disagreeing with business audit conclusions
• Timeline to file Petition for Redetermination?
• What should Petition for Redetermination contain?
• Is the appeals conference formal or informal?
• Appeals Division’s Decision and Recommendation
• Are a mark-up percentage and a profit margin the same?
• Problems with the mark up audit
• Can State Board of Equalization ignore my business records
• What is a sales tax deficiency determination?
• Business being audited for sales tax. Should I be worried?
• Audit determined fraud to avoid sales and use tax
• Definition of “sale” for California Sales Tax
• What do California sellers need to know about sales tax?
• How do I apply for a sellers permit?
• What are my obligations as a permit holder?
• What is sales tax?
• What is tangible personal property?
• What is a sale?
• What are total gross receipts?

• What is use tax?
• Who is responsible for paying the use tax?
• Who is a retailer engaged in business in California?
• Who is a qualified purchaser?
• Do I need a Certificate of Registration Use tax?
• Do I need a Use Tax Direct Payment Permit?
• What types of sales are exempt from sales tax?
• How are Internet Transactions Taxed?
• How is California sales or use tax determined?
• What is the statewide sales and use tax rate?
• Are there other local and district sales and use taxes?
• Total sales and use tax rate calculation
• How to protect against successor liability in California
• Recourse when issued California sales tax liability notice
• CA Sales Tax liability extend to purchasers/successors?
• Waiting Until Audited to Take Action on Tax Matters
• Sales tax records needed in California
• What are California’s sales and use taxes?
• Why does the State of California audit businesses to ensure compliance with sales and use taxes?
• How does the State determine whether to audit my business?
• The BOE reviews the purchase invoices of my business

Questions and Answers for Criminal Tax Representation

• When tax defense counsel parallels tax crime investigation
• Guilty of tax obstruction by backdating documents?
• To be found guilty of tax obstruction must a person actually be successful in impeding the IRS’s functions?
• Help! The Document I Gave the IRS Had False Information
• Tax crime aiding or assisting false return IRC §7206(2)
• What is the crime known as tax obstruction § 7212?
• What is the difference between tax perjury and tax evasion?
• What is the tax crime commonly known as tax perjury?
• What is a Klein Conspiracy?
• Increased possibility of civil action in IRS investigation
• Am I Guilty of Tax Evasion if the Law is Vague?
• What happens if the IRS thinks I committed tax crimes?
• What are ways to defend against a tax evasion charge?
• Difference between criminal tax evasion and civil tax fraud
• What accounting method does the IRS use for tax fraud
• Can I Change Accounting Method to the Accrual Method
• What is the willfulness requirement for tax evasion?
• I didn’t know I committed tax fraud. Can I get off?
• Concealed assets from IRS. Can I avoid tax evasion charges
• How government proves I willfully engaged in tax evasion
• What is the venue or court where a tax crime case is heard?
• Must the IRS prove tax crimes beyond a reasonable doubt?
• Is it a crime to make false statements to the IRS?
• Will the IRS overlook my tax evasion if it’s minor?
• Failed to tell IRS about my nominee account
• Audit risk with cash based business transactions
• How to defend a client charged with tax evasion
• Is it tax evasion if I didn’t file income tax return?
• Government says I attempted to evade my taxes. Now what?
• I forgot to pay my taxes or estimated tax. Is this a crime?
• Government proof I “willfully” failed to pay taxes
• 5 Ways to Respond to Tax Evasion Charges
• Being audited after using a tax professional
• Rules for what an IRS agent can do while investigating me
• How tax preparers, attorneys and accountants are punished
• How the IRS selects tax crime lead for investigation

• How does the IRS prosecute suspected tax crimes?
• Does IRS reward informant leads for suspected tax crimes?
• How the government proves deficiency in a tax evasion case
• Do prior tax crimes factor into new IRS tax convictions?
• Requesting conference before investigative report is done
• Requesting conference after IRS Special Agent Report
• What are my rights during an IRS criminal investigation?
• Avoid prosecution for tax crime with voluntary disclosure?
• Defense tactics that make it hard for to prove willfulness
• How a tax attorney can stop your criminal tax case?
• What can you generally tell me about tax crimes?
• Continuing filing requirement with investigation pending
• Federal criminal code crimes that apply to tax issues
• Penalty for making, subscribing, and filing a false return
• CID special agent’s report for criminal prosecution
• What is the discovery process in a criminal tax case?
• What the IRS includes in indictment for tax case
• What is the hardest element of a tax crime to prove?
• IRS methods of gathering evidence to prove tax crime
• What does a grand jury do in IRS tax crime prosecution?
• Failure to keep records or supply information
• Failure to make a return, supply information, or pay tax
• What is attempting to evade payment of taxes?
• What is income tax evasion and how is it punished?
• What is attempted income tax evasion?
• What is the crime of failure to pay tax? What is punishment
• Crime of making or subscribing false return or document
• Criminal Investigation Division investigation tactics
• Tax crimes related to employment tax forms and trust funds
• Tactics to defend or mitigate IRS criminal tax charges
• How the IRS generates leads about suspected tax crimes
• What is the crime” evasion of assessment” of tax?
• Specific examples of “attempting” to evade tax assessment
• What is the so-called Spies evasion doctrine?
• Does overstating deductions constitute tax evasion?
• Is it tax evasion if my W-4 contains false statements?
• IRC §7201 attempt to evade vs. common-law crime of attempt
• What are the penalties for Spies tax evasion?
• How government proves a taxpayer attempted tax fraud
• What is a tax that was “due and owing.”
• What is evasion of assessment for tax liability?
• Is evasion of assessment different from evasion of payment
• Does the IRS have a dollar threshold for tax fraud?
• What is the IRS burden of proof for tax fraud convictions?
• Are Tax Laws Constitutional?
• What is the source of law that defines tax evasion?
• Does section 7201 create two distinct criminal offenses?
• Does tax evasion definition include partnership LLC
• What if I helped someone else evade taxes?
• Is it illegal to overstate deductions on my tax return?
• Is it illegal to conceal bank accounts from the IRS?
• Do later losses justify prior deductions?
• Common reasons the IRS and DOJ start investigations
• What is the Mens Rea component of tax crimes?
• What is a proffer agreement and what are the risks?
• Why to have an attorney to review a proffer agreement
• Why enter into a proffer agreement?
• Limited use immunity from proffer agreements
• Difference between civil and criminal fraud allegation

Questions About Delinquent Payroll Taxes and Trust Fund Recovery Penalty

• What happens if an employer continues to incur new payroll tax liabilities?
• California Employment Taxes Basics
• How Does the IRS Develop an Employment Tax Fraud Case from the First Indication of Fraud to a Criminal Indictment?
• Can more than one person be considered responsible by IRS
• How unpaid employment tax payments are allocated
• When a corporate officer is considered a responsible party
• Examples of trust fund recovery penalty determinations
• Failing to pay employment taxes after notice is given
• How to determine responsible person for trust fund recovery
• Assessing trust fund recovery penalty and option to appeal
• What is the trust fund recovery penalty?
• What are the penalties for failure to pay employment taxes
• When am I considered liable for company’s employment taxes