San Diego Tax Attorney

Tax Defense. Tax Strategy.
One Firm That Does Both.

IRS problems require legal solutions. Tax savings require legal strategy. Brotman Law provides both — for businesses, individuals, and the CPAs who advise them.

As Featured In & Recognized By

Forbes Business Council

Tax Defense

IRS audits, criminal investigations, California state tax disputes, and tax debt resolution. When you need a tax attorney, we respond within one business day.

Tax Strategy

Exit planning, entity restructuring, real estate optimization, and proactive tax planning — the legal layer that goes beyond compliance.

ERC Defense

ERC litigation, audit defense, appeals, and voluntary disclosure. We're recovering millions in credits the IRS is trying to claw back.

About Brotman Law

Where Tax Law Meets Business Strategy

Brotman Law is a San Diego tax law firm founded by Sam Brotman, J.D., LL.M. (Taxation), MBA. We represent individuals and businesses in IRS disputes, California state tax controversies, and complex transactions — with more than 2,200 matters resolved since 2013.

Most firms handle tax defense or tax planning. We do both — because the best defense starts before a problem exists, and the best strategy accounts for how agencies actually enforce.

By the Numbers

Real Results for Real Clients

In Tax Penalties & Interest Eliminated

$ 0 M+

Audit Clients Represented

0 +

Appeal Victories

0 +

Client Results

Don't Take Our Word for It.

Our clients are the best measure of what we do.

“Brotman Law solved my tax problem and secured the long term financial future of my business and my family.”

Business Owner — Tax Debt Resolution

“Sam’s team successfully closed our EDD case and got us an outcome I didn’t think was possible.”

EDD case resolved

Restaurant Owner — California EDD Audit

“Brotman Law helped us reduce our potential liability by 97%!”

97% liability reduction

Business Owner — IRS Audit Defense

Beyond Compliance

Tax Strategy, Exit Planning & Transactions

Tax defense gets the headlines, but proactive tax strategy is where the real money is saved. We work with business owners, real estate investors, and high-net-worth individuals to legally minimize what they owe — before a problem ever starts.

Exit planning & M&A tax structuring for business sales
Real estate portfolio optimization & 1031 exchange strategy
Entity restructuring & multi-state tax planning
Income deferral, trust strategies & succession planning
$400M+ in corporate transactions structured for tax efficiency

The Brotman Difference

Tax Compliance Is the Floor. Strategy Is How You Win.

Most CPAs and accountants focus on one thing: filing your return correctly. That’s compliance. It’s necessary, but it’s not enough. Real tax savings come from proactively structuring your business, income, investments, and transactions before the tax year closes — not just reporting what already happened.

At Brotman Law, we sit at the intersection of tax law and strategy. We don’t just keep you out of trouble — we help you legally keep more of what you earn.

What's the Difference in Practice?

Compliance Only

Brotman Law Strategy

Timing

Reactive — after the tax year ends

Proactive — structured before year-end

Goal

Accurate filing and avoiding penalties

Legally minimizing total tax paid

Approach

Report what happened

Structure what happens — before it does

Audit Risk

Unmanaged — depends on filing accuracy alone

Actively managed — positions documented to withstand scrutiny

Outcome

Pay what the IRS says you owe

Pay what the tax code legally requires — often far less

Case Study

$905K Multi-Agency Debt Resolved

Business Saved, Owner Protected

The Challenge

A California manufacturing business owner faced simultaneous collection actions from three separate tax agencies — totaling $905,000 in combined liabilities. With three agencies moving independently and no coordination between them, the business was being squeezed from every angle.

IRS

$430K

Unpaid Form 941 payroll taxes — federal tax lien filed, receivables levy threatened

FTB

$185K

Corporate income tax — lien placed on owner’s personal residence

EDD

$290K

Worker reclassification audit — owner’s personal wages being garnished

Our Strategy

We developed a unified resolution strategy that addressed all three agencies simultaneously, sequencing each move to protect leverage with the others.

IRS

Negotiated a 72-month installment agreement with a partial-pay structure — monthly payments based on the company’s actual disposable income, with the remaining balance set to expire with the collection statute.

FTB

Filed an Offer in Compromise demonstrating that the company’s California-specific collection potential was limited — settling the $185,000 liability for $52,000 paid over 12 months.

EDD

Appealed the worker reclassification to the California Unemployment Insurance Appeals Board (CUIAB). Presented evidence that 60% of the reclassified workers maintained independent businesses. CUIAB reversed the reclassification — reducing the EDD assessment from $290,000 to $116,000.

The Outcome

All three agencies in active resolution
Federal tax lien subordinated to enable working capital financing
Wage garnishment released
Business continues operating with 40+ employees
Owner's personal assets fully protected
Multi-year payment plans align with actual cash flow

Details have been changed to protect client confidentiality. Prior results do not guarantee a similar outcome.

Our Team

People Do Business With People.

Every person at this firm — from our attorneys to our operations team — is someone we’d trust with our own tax situation. They’re sharp, they care, and they don’t stop until the job is done.

Get Started Today

Book Your Free 15-Minute Call

Schedule a brief call with our team to discuss your situation. We’ll assess where things stand and outline your options — confidentially and without obligation.

or call us directly