Los Angeles Tax Attorney — California IRS and State Tax Defense

Written by Sam Brotman, J.D., LL.M. (Taxation), MBA — Managing Attorney, Brotman Law  ·  Updated May 2026

What Sam Does for Los Angeles Clients

A tax attorney handles IRS and California tax disputes as legal matters — not accounting problems. The distinction matters when the IRS is questioning whether you reported income correctly, when an examiner is building a fraud narrative, or when the FTB is challenging your California residency. Those are legal disputes with legal consequences. They require someone who can represent you in the proceedings, assert your rights, and know when a civil issue has criminal exposure.

I represent Los Angeles clients across the full range of federal and California tax matters: IRS audits, IRS Criminal Investigation defense, tax debt (Offers in Compromise, installment agreements, levy releases), FTB audits and appeals, EDD and CDTFA disputes, and FBAR and foreign account compliance. The cases that come from LA tend to look the same as the ones from San Diego — high-income individuals, business owners, real estate, and international issues are the common threads.

What makes this practice different: I am both an attorney and a CPA. That dual credential is relevant — not as a resume line, but as a practical matter for the kinds of cases LA clients bring. See the section on why that matters below.

IRS and California Tax Problems Sam Handles for LA Clients

IRS Audits

An IRS audit is a legal examination of whether your return is correct — and how you handle it determines whether it stays civil or becomes something more serious. The IRS Los Angeles field office is located at 600 Wilshire Boulevard. Field examiners from that office conduct audits of LA-area individuals and businesses; Examination and Appeals cases also come through the Southern California territory.

I handle correspondence audits, office exams, and full field examinations. The more complex the audit — multiple tax years, substantial unreported income, business audits with multiple issues — the more important it is to have representation from the beginning rather than trying to manage it yourself and calling an attorney when things go sideways. See our full guide to IRS audit defense.

IRS Criminal Investigation

When IRS Criminal Investigation (CI) is involved, the case is no longer an audit — it is a federal law enforcement matter. CI special agents are armed federal officers with the authority to arrest, execute search warrants, and refer cases for prosecution by the Department of Justice Tax Division. Their conviction rate historically runs above 90%.

CI has an active Los Angeles field office. Cases involving unreported income, offshore accounts, employment tax fraud, and tax-related money laundering are common in the LA market. If a CI special agent has contacted you or you have reason to believe an investigation may be open, coordinate with a criminal tax defense attorney before responding to investigators. I handle CI defense from the preliminary investigation stage through DOJ Tax Division review and, where cases proceed, through trial. See our practice area page on IRS Criminal Investigation.

IRS Collections — Levy, Lien, and Offer in Compromise

The IRS has significant collection tools: federal tax liens, bank levies, wage garnishments, and seizure of assets. California taxpayers who owe back taxes are subject to the same federal collection procedures as taxpayers anywhere in the country. A federal tax lien attaches to all property — real estate, financial accounts, business assets — and can materially affect your credit, your business operations, and your ability to sell or refinance property.

I represent LA clients in IRS collections across the full range of resolution options: installment agreements, Offers in Compromise (OIC), currently-not-collectible determinations, Collection Due Process (CDP) hearings, and innocent spouse claims. An Offer in Compromise (OIC) is a settlement with the IRS for less than you owe — it requires demonstrating that your Reasonable Collection Potential (RCP), calculated using Form 433-A or 433-B, supports the offered amount. Most offers get rejected because the analysis was not done correctly before filing. That is the right place to start.

FTB Audits — California Franchise Tax Board

The California Franchise Tax Board audits personal income tax returns, and residency audits in particular are a significant issue for LA-area taxpayers with connections to other states. The FTB Los Angeles district office handles examinations for Southern California residents. California is aggressive about residency determinations — the state taxes its residents on worldwide income, and the FTB scrutinizes high-income individuals who claim to have changed domicile.

FTB audits can involve income reporting disputes, passive activity loss questions, and, for business owners, whether California has nexus to tax income that the taxpayer allocated elsewhere. I handle FTB audits, administrative appeals before the Office of Tax Appeals (OTA), and FTB collections. See our practice page on FTB audit defense.

EDD and CDTFA Disputes

California's Employment Development Department (EDD) and California Department of Tax and Fee Administration (CDTFA) both have audit and enforcement authority that operates independently of federal IRS matters. EDD audits focus on worker classification — whether individuals you paid as independent contractors should have been classified as employees, triggering payroll tax liability. CDTFA audits cover sales and use tax, often for retail businesses, restaurants, and contractors.

LA has a large and varied business community, and EDD and CDTFA audits are common for business owners in the area. I represent LA clients in EDD worker classification disputes and CDTFA sales tax audits and appeals.

FBAR and International Tax

Los Angeles has a substantial population of taxpayers with foreign financial accounts, foreign income, and international business structures — and the IRS and DOJ have been consistent in their enforcement of FBAR and related foreign account reporting requirements. A FinCEN Form 114 (FBAR) must be filed annually by U.S. persons with foreign financial accounts exceeding $10,000 in aggregate value at any point during the year. Willful failure to file carries civil penalties up to the greater of $100,000 or 50% of the account value per year, and can result in criminal prosecution under 31 U.S.C. § 5322.

I handle FBAR compliance, amended returns for unreported foreign accounts, and the streamlined filing procedures for non-willful violations. For situations with willful exposure, the voluntary disclosure program (IRM 9.4.3) is the appropriate framework — and it is available only before CI has made contact.

Why Los Angeles Taxpayers Work with Sam

Sam Brotman is both a California-licensed attorney and a licensed CPA — a dual credential that is directly relevant to the complexity of most serious tax cases.

Here is what that means in practice. A CPA who is not an attorney cannot invoke attorney-client privilege. Anything your CPA knows about your situation — your unreported income, your account structure, your prior filings — can be subpoenaed in a civil or criminal proceeding. An attorney can. When I take on a case, communications about the facts are protected. If I need to use an accountant's work to build the defense, I can retain that accountant under a Kovel arrangement that extends attorney-client privilege to their work product.

The CPA credential also means I can work directly in the numbers without needing to hand off every financial question to a separate expert. In an IRS audit, that matters — examiners use accounting-based arguments, and responding to them competently requires understanding both the legal framework and the accounting. In an Offer in Compromise or collection case, the financial analysis (Form 433-A, Reasonable Collection Potential, allowable expenses under IRS Collection Financial Standards) is the substance of the case. I do that analysis in-house.

Since 2013, Brotman Law has represented over 400 clients in audits and has recovered or saved $1B+ in taxes and penalties. Those numbers come from real cases — IRS audits resolved favorably, offers accepted, criminal investigations resolved without charges, and collection disputes closed.

The practical advantage of working with a California attorney in San Diego for an LA matter is this: the costs are lower than an LA firm with equivalent credentials, the practice is focused on tax (not a general practice that also does tax), and the geographic reality of a statewide California practice means LA cases are a routine part of what we handle — not an exception.

How LA Clients Work with Sam

Most of the work in a tax representation happens in writing, over the phone, and through document exchange — not in a physical office. IRS and California tax matters are driven by correspondence, document production, and formal proceedings, the vast majority of which can be handled remotely for LA-area clients.

The typical workflow for an LA client: we start with a phone or video consultation to go through your situation and what you are facing. If it makes sense to move forward, we get a signed engagement agreement and a Form 2848 Power of Attorney authorizing me to represent you before the IRS. From there, I obtain your transcripts, communicate directly with the IRS or California agency, and handle the case. You hear from me at substantive decision points — not a weekly status call about nothing.

I am based in San Diego — 12636 High Bluff Drive, Suite 400, San Diego, CA 92130. For clients who prefer in-person meetings, that office is available and the drive from LA is manageable for most people when the meeting is worthwhile. For IRS hearings and Tax Court proceedings in Los Angeles, I travel. Federal Tax Court sessions are held in Los Angeles, and the IRS Appeals office handles LA matters independently of my location.

The honest framing: a lot of tax representation is phone calls, letters, and negotiations that do not require geographic proximity. What matters is whether your attorney knows what they are doing, has handled cases like yours, and can get the IRS or the FTB to a reasonable result. That is not a function of which city the attorney's office is in.

Sam's Credentials

Samuel C. Brotman, Esq., CPA, is the managing attorney of Brotman Law, a California tax law firm founded in San Diego in 2013.

• California State Bar — licensed attorney, admitted to practice in all California courts and before federal courts in the state
• Certified Public Accountant (CPA) — California-licensed CPA in addition to his law license; the dual credential is uncommon at the managing-attorney level
• J.D., LL.M. (Taxation), MBA — graduate tax law degree in addition to the J.D. and MBA; the LL.M. in taxation is the specialized postgraduate degree for tax lawyers
• IRS Representation — authorized to represent clients before all divisions of the IRS under Form 2848, including Examination, Appeals, and Collection
• Practice since 2013 — Brotman Law has focused on tax representation since its founding; this is not a general-practice firm that also handles tax matters

You can reach our San Diego office at (619) 378-3138. For an initial conversation about your LA matter, book a free 15-minute call and we can figure out whether this is right up our alley.