TAX AUDIT AND APPEAL REPRESENTATION

Tax audits by the IRS and the California Franchise Tax Board (FTB) have become more complex and intrusive.   Sales and use tax audits by the California State Board of Equalization (BOE) and employment tax audits by the Employment Development Department (EDD) can lead to large assessments against businesses.  Failing to respond to an audit notice from the IRS can lead to a loss of appeal rights, a loss of your right to petition U.S. Tax Court, and hundreds of thousands of dollars in additional tax owed.  Failure to respond to an audit notice from a state tax agency can have similarly devastating consequences.

If you receive an audit notice from the IRS or a state tax agency, it is important to obtain competent professional help.  Robert Horwitz has represented individuals, business entities, estates and trusts in income tax, estate and gift tax, employment tax, excise tax and sales tax audits.  He has worked with clients and their accountants in order to resolve audits in as favorable a manner as possible. 

Where an audit cannot be resolved at the examination level, a taxpayer is often given a right to appeal to the IRS Office of Appeals in federal tax audit.  A taxpayer in a state tax audit is given a right to protest administratively.  Settlement of a case with the IRS Office of Appeals or the Settlement Bureau of the Franchise Tax Board is often the most cost effective way of resolving disputes with an auditor's determination. 

Among the areas in which Robert Horwitz has represented clients in audits and appeals are:

Income tax audits by the IRS and FTB

Estate and gift tax audits

Employment tax audits by the IRS and EDD

Sales tax audits by the BOE

Trust fund recovery penalty investigations by the IRS

Responsible person investigations by BOE and EDD

Audits of offshore accounts and income

FBAR penalty investigations and appeals

Return preparer and tax shelter promoter penalty audits

TEFRA Partnership Audits

Tax shelter investigations and audits

California residency disputes