Tax Controversy

Dave represents individuals and businesses with tax controversy matters before the federal and state taxing authorities. Dave regularly represents taxpayers in civil matters before the Internal Revenue Service Examination and Appeals Divisions and the U.S. Department of Labor, Wage and Hour Division. Dave’s state tax practice focuses on controversy work involving income, employment, and transfer taxes imposed and enforced by California state agencies, including the Franchise Tax Board, State Board of Equalization, Employment Development Department, and Department of Labor. Dave’s areas of expertise includes civil tax audits, administrative appeals, collection disputes and civil tax litigation before the U.S. Tax Court.

Dave has litigated a wide range of tax issues, including:

• employee-independent contractor status
• business expenses
• innocent spouse relief
• real property tax assessments
• refunds
• qualified small business stock
• minimum wage and overtime
• reasonable compensation
• civil fraud and accuracy related penalties

Dave’s tax collection defense experience includes handling:

• collection due process hearings to prevent levies
• lien foreclosure lawsuits
• negotiating installment agreements
• offers in compromise