State & Local Tax Investigations

The goal of Moskowitz, LLP’s civil and criminal tax defense team is to use our experience and understanding of the tax code, tax procedures, and tax system to resolve your tax issue before any criminal charges are filed against you and before the investigation goes public.

California tax investigations

Although California models many of its policies and procedures after the IRS, we have found that on the whole the FTB’s investigations and settlement procedures are far more demanding. The FTB has more levels of administrative review than the IRS, more detailed information disclosures, and a very slow settlement process.

State and local tax audits and investigations are generally carried out when an individual, corporation, or partnership engages in activities including, but not limited to:

  • Misappropriation of sales tax and/or employment tax trust funds
  • Misclassifying employees as independent contractors
  • Paying employees off-the-books
  • Failing to file tax returns
  • Filing false tax returns
  • Tax refund fraud

Our firm has also resolved many state tax disputes regarding California residency and income-sourcing.

FTB collections

The FTB is also more aggressive than the IRS in its collections process. If you fail to dispute your case in a timely manner, the FTB may:

  • Seize your assets
  • Freeze your bank account
  • Garnish your wages
  • Revoke your business, professional, and/or driver’s license

If you miss the deadline for a state tax appeal (generally 30 days from receipt of a Notice of Action or Notice of Determination), you will probably need to pay the tax and then file a claim for a refund.

San Francisco tax defense attorneys

The experienced tax defense attorneys at Moskowitz LLP work tirelessly to provide top notch tax controversy representation that ensures the best possible outcome for the firm’s state and local tax clients. Contact our San Francisco office to put our knowledge and experience to work for you.

Get in Touch With Us