Tax Audits, Protests, and Appeals

Tax attorney Daniel W. Layton, Esq., an ex-IRS trial attorney, represents Orange County and South Bay clients in sophisticated tax audits, protests and appeals before the IRS, the FTB, the CDTFA, the EDD, and the county assessor’s office. Handling tax controversies requires not only the ability to understand complex tax issues, but also extensive familiarity with the government’s practices and procedures to protect and avail you of your rights. Mr. Layton's inside-knowledge allows him to present our clients’ cases in a way that forces the IRS or state tax agency to listen and give them a fair hearing. Mr. Layton has exceptional experience in handling and favorably resolving matters at the audit, the administrative protest and the appeal stages, including:

  • Corporate, Partnership, LLC, and Small Business Income Tax Audits and Examinations
  • Unreported Income and Bank Deposit Reconciliation/Analysis Audits
  • Franchise Tax Board and IRS Appeals and Protests of Proposed Tax Assessments
  • Penalty Waivers, Penalty Abatements, and Penalty Appeals
  • Employment Tax Appeals and Payroll Tax Appeals (IRS and Employment Development Department)
  • Trust Fund Recovery Penalty Appeals
  • Unfiled Return and “Substitute for Return” Appeals and Protests
  • CDTFA (California Department of Tax and Fee Administration, formerly BOE) Sales & Use Tax Audits and Appeals

When dealing with the IRS or the State of California, it matters who represents you. Agents and lawyers for the IRS, the FTB, and other government agencies often rely on their specialized knowledge of government procedures and familiarity with the rules for a “home field advantage.” In addition, government agents and lawyers perceive an advantage when they deal with taxpayer representatives who aren’t known for taking righteous cases all the way to judicial verdict if necessary. Mr. Layton's history of putting his opponents’ feet to the fire and taking worthy cases to trial, if necessary, levels the playing field for his clients.

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