There are many tax attorneys in California. Most of these attorneys concentrate on tax planning strategies. However, very few tax attorneys are tax litigation, or tax controversy, lawyers. Tax controversy lawyers represent clients who have disputes with the IRS or California taxing authorities. For example, if you or your business is undergoing a tax audit, a tax controversy attorney can represent you at the audit or an appeal from a tax audit. A tax controversy lawyer can represent you in the appropriate California Court, the U.S. Tax Court or other appropriate court which may include the U.S. District Court, Court of Federal Claims, or even the Bankruptcy Court. A tax controversy lawyer can also represent you if you have a tax collection matter, and would an offer in compromise or in installment agreement to pay your tax debt. In addition, a tax controversy attorney can represent you in the abatement (elimination) of interest and penalties, in summons enforcement actions, wrongful levy actions, and in wrongful disclosure lawsuits. A tax controversy attorney can represent you if you become subject to enforcement proceedings, including injunction proceedings against a tax preparer as well as an alleged violation of Circular 230 by a tax preparer.

The skills and knowledge necessary to be an effective tax controversy attorney are not the same as those necessary to be a tax planning attorney. A tax controversy attorney must understand not only the tax law, but also the administrative procedures that govern the day-to-day workings of the IRS or California taxing authority. IRS revenue agents, tax auditors, revenue officers, and appeals officers frequently rely on the Internal Revenue Manual – a huge document which lays out in minute detail the rules that IRS employees are supposed to follow. Tax controversy lawyers must also have an understanding of the various statutes of limitation which can prevent the taxing authorities from pursuing you for taxes.

A tax controversy lawyer must also understand the rules of evidence and the rules of procedure of the California and United States courts in which a tax controversy case can be litigated. A tax controversy attorney should be able to advise you concerning the advantages and disadvantages of appearing in each of these courts. Even if you don’t think that you want to litigate your tax dispute, just having a tax controversy lawyer with litigation experience will increase your credibility with the IRS and State taxing authorities and increase your chances of obtaining a favorable settlement.

Dennis M. Sandoval is one of only ________ lawyers in Riverside County who is a Certified Taxation Law Specialist by the California Bar Board of Legal Specialization. He also has a Master of Tax Law degree. Prior to becoming an attorney, Dennis passed the Enrolled Agent exam to practice before the Internal Revenue Service. Prior to the creation of his own firm, he was employed, first as a law clerk, and then as an associate attorney, with one of the largest tax controversy law firms in Orange County. He has handled cases involving income tax, gift tax, estate tax, sales tax, employment tax and property tax and he has handled tax law related cases in the California Superior Court, California Court of Appeals, U.S. Tax Court, U.S. District Court and Ninth Circuit Court of Appeals.