I would tell you that sales tax audits are very complicated. They're complicated because of the amount of data involved. They're complicated because they involve statistics and they're complicated because sales tax law is kind of a different animal than basic federal income tax law. Unless the people from your company or you personally have experienced dealing with sales tax audits, I almost never recommend that a client handle the audit themselves even if the client is going to work to prepare the documents necessary for the audit and do the prep work. I always maintain that it's better to have a representative as the face of the audit versus having the client do it themselves. With respect to CPAs, the biggest problem that I see with CPA representation is that a lot of CPAs come from a compliance background and what I mean by that is when you're a CPA, your job is to fill out tax forms and to fill them out accurately. The term certified public accountant means that you have public trust in preparing financial statements. That's where CPA comes from. When you're thinking about compliance oftentimes it's very hard to shift into an advocacy focus and the difference between attorneys and CPAs is that attorneys mostly live on the advocacy side of things. So whereas most CPAs are compliance based (for example perceiving an audit notice with a document request and turning over all the documents to the auditor) a tax attorney would know to fight that. It's not to say that some CPAs can't be good advocates for their clients. In fact we know many that are and in fact that technical accounting background plays very well in a sales tax audit because oftentimes the sales tax auditor has their own background in accounting, but you want to make sure that there's an advocacy component of it because knowing the sales tax law isn't everything. The knowledge of tax procedure in a sales tax audit is really critical to success in the audit. You want to have a representative that can not only handle the audit, but can handle any subsequent appeals, that can deal with the settlement section of CDTFA or who can go litigate the case at the office of tax appeals in California. If absolutely necessary, because of this, most CPAs that I know that do sales tax audits are only limited to the audit level and while they do a very fine job,

I think the client is better served in a lot of situations, particularly when there's any risk involved, by having somebody who's more comfortable at the higher levels and can provide a much broader representation of the client. By far the biggest successes that we've had in the appeals process are those audits that we've handled initially, because we're able to load the record at the audit level with things that are going to help us later in Appeals. Whenever we do a sales tax audit as a firm, we're constantly building the record and putting information in there that we know we're going to have success on either at the settlement level or the Appeals level. If you don't have familiarity with the highest levels of the process it's really hard to do that during the course of the audit.