When a Tax Authority Comes Knocking, Credentials Matter

Receiving a notice from the IRS or the California Franchise Tax Board is unsettling, even when you have done nothing wrong. Tax disputes move quickly, deadlines are unforgiving, and the wrong response at the wrong stage can significantly worsen your position. This is not the time for general legal representation.

Michael R. Brown brings a combination of credentials that is rare in tax dispute work. He is a licensed attorney, a Certified Public Accountant, and holds the California State Bar’s designation as a Certified Tax Specialist. Before founding Brown and Brown in Laguna Hills, he worked in the tax department of Arthur Andersen & Co., one of the largest accounting and professional services firms of its era. He has been representing Orange County individuals and businesses in tax disputes since 1987.

That background means he understands how tax authorities build their positions and where those positions have weaknesses. He reads your return the way an auditor reads it. He understands the procedural rules, the appeal rights, and the settlement options at every stage of the dispute process.

Brown and Brown represents clients in tax disputes at all levels from initial audit response through administrative appeals, offers in compromise, and Tax Court litigation when necessary.

Tax Dispute Resolution Services

IRS Audit Representation An IRS audit whether conducted by correspondence, at an IRS office, or as a field examination at your home or business requires careful, coordinated management. Every document you provide and every statement made during the audit process shapes the outcome. We manage the communication, gather and organize the supporting documentation, respond to examiner inquiries, and work to resolve the audit on the most favorable terms the facts support.
IRS Appeals If an IRS auditor issues findings you disagree with, you have the right to appeal to the IRS Independent Office of Appeals before any tax is assessed. The appeals process is often the most productive stage of a tax dispute.  An experienced representative who understands the hazards of litigation for both sides can frequently negotiate a resolution that neither party would have reached at the examination level. We represent clients through the appeals process with that outcome in mind.
Franchise Tax Board (FTB) Disputes California’s Franchise Tax Board is an aggressive tax authority with its own audit and collections procedures distinct from the IRS. We represent California taxpayers in FTB audits, protests, appeals, and collections matters, including disputes over residency determinations, income sourcing, and business income allocation that are particularly common for high-income individuals and business owners in Orange County.
State Board of Equalization and CDTFA Sales tax, use tax, and other tax matters administered by the California Department of Tax and Fee Administration (CDTFA, formerly the Board of Equalization) require specialized knowledge of California’s tax rules for businesses. We represent business owners in audits and appeals before these authorities.
Tax Assessor Disputes Property tax assessments that you believe overstate the value of your property can be challenged through the county assessment appeals process. We advise clients on the grounds for appeal and represent them through the process.
Offers in Compromise If you owe more to the IRS or California than you can reasonably pay, an Offer in Compromise may allow you to settle your tax liability for less than the full amount owed. The IRS and FTB each have their own Offer in Compromise programs with distinct eligibility standards and procedures. We evaluate whether you qualify, prepare the submission, and negotiate with the tax authority on your behalf.
Tax Liens and Levies A federal or state tax lien damages your credit and can encumber your property. A levy whether against your bank account, wages, or other assets can be devastating. We work to release liens and levies and negotiate collection alternatives including installment agreements and currently-not-collectible status when appropriate.
Tax Penalty Abatement Many taxpayers who owe back taxes face penalties that substantially increase the total balance due. First-time penalty abatement and reasonable cause abatement are legitimate IRS programs that can remove those penalties entirely in the right circumstances. We evaluate your situation and pursue abatement where the grounds exist.

The Advantage of an Attorney Who Is Also a CPA

Most tax disputes are won or lost on the numbers: the specific items on a return, the documentation that supports them, and the legal standard that applies to each. An attorney who is also a CPA can analyze both simultaneously. Michael Brown reads the tax return as an accountant and understands the legal standards that govern each line. That dual perspective is a material advantage in audit representation, appeals, and litigation.

It also means he understands what your accountant was doing when the return was prepared, which is often the starting point for understanding what the IRS is questioning and why.

Frequently Asked Questions

About Tax Disputes

Since

Years-Experience-Bedge

1987

Schedule a Free Tax Dispute Consultation

If you have received a notice from the IRS, the Franchise Tax Board, or another tax authority or if you anticipate a tax dispute early consultation with an experienced tax attorney makes a meaningful difference in outcomes. We offer a free initial consultation to discuss your situation and explain your options.

Brown and Brown, A Law Corporation
23041 Mill Creek Drive, Laguna Hills, CA 92653
(949) 389-2209
jesse@browntaxlaw.com
Schedule Your Free Consultation