Wilson Law Tax Group believes that a taxpayer should only litigate against the IRS or the state taxing authorities after all other alternatives of resolving a tax dispute have been exhausted. In audits conducted by the Internal Revenue Service (IRS), the California Employment Development Department (EDD), the California State Board of Equalization (BOE), or the California Franchise Tax Board (FTB), Wilson Tax Law Group represents clients and works with their accountants in resolving an audit in a manner most favorable to our clients. Wilson Tax Law Group strives to resolve the matter at the audit level and prepares to proceed to the Appeals Office or to litigation if the audit is not resolved in a favorable manner to the client. Wilson Tax Law Group believes that the Appeals Office and/or the Settlement Division generally offers a favorable venue to resolve disputes short of litigation.

Sample matters can include:

  • • Income tax audits by the Internal Revenue Service and the California Franchise Tax Board
  • • Estate and gift tax audits by the Internal Revenue Service
  • • Employment tax audits by the Internal Revenue Service and the California Employment Development Department
  • • Sales tax audits by the California State Board of Equalization
  • Return Preparer Penalty Cases
  • • Trust Fund Recovery Penalty investigations
  • • Offshore income tax disputes, foreign income, bank and asset reporting, and related penalties
  • • TEFRA Partnership Audits and FPAA determinations
  • • Tax shelter investigations, audits and litigation
  • • Tax shelter promoter audits and investigations
  • • Filing administrative appeals, representing taxpayers at appeals conferences, negotiating settlements
  • • California residency disputes