Tax Litigation Lawyer In Los Angeles, California
The Law Offices of Robert T. Leonard, APC in Westlake Village, serving Greater Los Angeles, is a dedicated tax litigation law firm. When tax controversies arise individually or are related to a business, the impact often has a ripple effect on many aspects of a person’s life. If you are facing a tax controversy or litigation, you deserve to work one-on-one with a lawyer who has a deep understanding of tax law – as well as the full financial implications that may ensue.
Our tax controversy attorney, Robert T. Leonard, brings over 30 years of experience in the law, fortified with his experience and knowledge as a CPA (inactive), to resolve tax problems holistically. You will work exclusively with Rob, who is attentive not only to the direct tax problem but also to the full scope of financial issues that may arise in relation to the core tax problem.
Scope Of Tax Litigation
Civil and criminal tax litigation involving the IRS or any other government agencies is a matter of utmost importance. Tax audits can result in penalties, collection actions and criminal charges as a result of:
- Failure to file
- Unpaid taxes
- Tax evasion
- Tax fraud
- Employment tax underpayment
- Not responding to a Notice of Deficiency
- Corporate tax underpayment/underreporting
- Income tax under withholding and reporting
- Sales and use tax understatements
- Unpaid interest and penalties from prior periods
- Failure to meet the terms of agreements with taxing authorities
Types Of Tax Disputes We Handle
IRS And State Tax Audits
Tax agencies review the accounts of people and businesses to check for compliance with federal and California laws. These audits vary in scope. Some are simple mail-in requests for records. Others are full field exams by the IRS, the Franchise Tax Board (FTB), or the California Department of Tax and Fee Administration (CDTFA).
Notice of Proposed Assessment And Administrative Appeals
Federal and state agencies issue notices when they believe you underpaid your taxes. You have the right to protest these findings. We represent you during this process. We work with the IRS Office of Appeals or the California Office of Tax Appeals (OTA) to challenge the audit before the bill becomes final.
U.S. Tax Court And State Tax Litigation
You can challenge a tax assessment in court. The U.S. Tax Court often allows you to sue before you pay the debt. However, California is a “pay-to-play” state. You must usually pay the state tax first. Then, you can file a lawsuit in Superior Court to seek a refund.
Civil And Criminal Tax Defense
We defend you against claims of tax evasion or negligence. Civil defense aims to avoid willful penalties. These include the Trust Fund Recovery Penalty or personal state assessments. Criminal defense involves cases led by the IRS Criminal Investigation (CI) or state police. These cases carry a risk of jail time.
Tax Debt Resolution And Collection Defense
This stage involves managing unpaid taxes that the government is trying to collect. We use the Collection Due Process (CDP) for federal debts and Collection Appeals for state debts. These tools are used to stop or lift bank levies, wage garnishments, and property liens.
Penalty Abatement And Interest Reduction
You can ask the government to remove penalties if you have a reasonable cause. Examples include a serious illness or a death in the family. Federal taxpayers may also use the First-Time Abate policy. California offers a One-Time Abatement for some individuals. Interest is harder to reduce. You must prove the government caused a delay or made an error.
Payroll, Sales And Business Tax Disputes
These disputes involve taxes you collect from employees or customers. They are high-risk cases. The government can hold business owners personally liable for the debt. In California, you may be personally liable for sales tax if you close or abandon your business.
Installment Agreement And Offer In Compromise Defense
You can settle your debt if you cannot pay it in full. An Installment Agreement lets you make monthly payments. An Offer in Compromise (OIC) is a different option. Both the IRS and California agencies have OIC programs. These programs allow you to settle the debt for less than you owe based on what you can afford to pay.
Our representation is aggressive, client-focused and results-oriented. We understand that a tax dispute can have devastating effects on your business and personal life. No matter what tax problem you may be facing, we will strive to provide you with the best legal counsel to get your life and business back on track so you can continue to focus on your success.
Settling Tax Disputes Outside Of Court
The assistance of a skilled tax dispute attorney can sometimes avoid litigation by strengthening your bargaining position. We can effectively navigate your situation and work for a resolution outside of the court process, including:
- Tax adjustments
- Reduction of tax penalties/interest
- Administrative settlements and appeals
- Offers in compromise (OICs)
- Installment payment agreements
- Petitions to the IRS for re-examination of the facts/books
As an experienced tax lawyer, Rob is qualified and prepared to appeal tax matters until a final and fair resolution of the matter can be accomplished. He has the experience as an effective tax litigator that allows him to advocate zealously on behalf of clients facing tax issues at any level.
Talk To An Experienced Tax Litigation Lawyer Today
If you have a pending tax matter and want to discuss the development and implementation of the right action plan for your tax litigation issue, call Rob 818-485-2115, or contact us online to schedule a free consultation. We serve clients in Los Angeles, Ventura, San Bernardino and Riverside counties, as well as those across California and throughout the United States.

