TAX LAW
Tax disputes, litigation and criminal tax defense for individuals and businesses
A tax dispute can affect an individual’s finances, a business’s operations and an owner’s personal exposure at the same time. Based in San Francisco, RV Litigation Group PC assists individuals, business owners and entities throughout California with IRS and state tax controversies, litigation and criminal tax concerns. The starting point is the actual notice, the disputed issue and the next decision that must be made.
PRACTICE AREAS
Tax Law Services
IRS Audits & Appeals
Representation in federal examinations, disputed adjustments and administrative appeals.
California Tax Disputes
FTB examinations, proposed assessments, protests and Office of Tax Appeals proceedings.
Tax Litigation & Appeals
Court-related strategy, evidence development and review of available tax litigation and appeal routes.
Criminal Tax Defense
Defense involving alleged tax evasion, false returns, employment-tax offenses and related investigations.
Tax Penalty Relief
Penalty review, supporting evidence, relief requests and administrative challenges.
Tax Liens, Levies & Collection Appeals
Lien and levy review, collection hearing requests and resolution options.
Payroll Tax Disputes
Employer payroll assessments, deposit disputes and trust fund penalty defense.
OUR APPROACH
One Dispute May Require More Than One Perspective
An agency may question a deduction, the treatment of a business transaction or a position taken on an individual return. The relevant evidence may sit across accounting files, contracts and communications. We work to connect that record to the legal issue and the available procedure.
Tax representation should distinguish an examination, an administrative appeal, a court case and a criminal investigation. Each calls for different decisions. Related federal and California matters also need coordinated attention without assuming that one response satisfies both agencies.
When allegations concern intentional misconduct, Criminal Tax Defense connects this practice with our White-Collar Defense work. The scope of representation is assessed in light of the client, the forum and the nature of the dispute.
THE PROCESS
How We Approach Your Matter
Review the notice and procedural history
Identify the agency, tax periods, proposed findings, existing submissions and any response or filing deadline.
Develop the facts and legal position
Organize the records and identify the disputed treatment, missing evidence and legal questions that drive the matter.
Choose the appropriate response
Assess the available audit response, protest, administrative appeal, litigation or defense route.
Evaluate resolution and next steps
Consider the consequences of proposed terms, remaining deadlines and any further review that may be available.
WHAT TO EXPECT
Important Points to Keep in View
Individuals and Businesses
The practice includes personal tax disputes as well as entity and owner-level matters.
The Notice Controls the Next Step
Different notices create different response obligations and review opportunities.
Preserve the Complete Record
Keep returns, supporting documents, agency correspondence and evidence of delivery.
Coordinate Related Matters
Federal, state and criminal issues may overlap while retaining separate procedures.
COMMON QUESTIONS
Frequently Asked Questions
Do you handle individual tax matters as well as business matters?
Yes. The tax practice includes disputes involving individuals, business owners and entities. We assess the particular notice, issues and representation needed rather than limiting the practice to one type of taxpayer.
Is tax litigation the same as an administrative appeal?
No. An administrative appeal asks an agency or administrative body to review a dispute. Litigation involves a court and its jurisdiction and filing rules. The available route depends on the tax, notice and procedural history.
What should I send when I receive a tax notice?
Begin with the complete notice, any stated deadline and a brief explanation of prior agency contact. Preserve the relevant returns and supporting records. The firm can identify what additional material is appropriate after an initial review.
Discuss Your Tax Matter
Tell our legal team which agency contacted you, whether the matter concerns you or a business, and any pending deadline so we can assess the appropriate next step.
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