The IRS isn't the toughest tax collection agency out there. By all accounts that title is held by the California Franchise Tax Board ("FTB"). The FTB seldom compromises, at any level. With the State in financial shock, the FTB is more daunting than ever.
High-asset individuals in California know that a FTB Audit is no afternoon at Malibu. The FTB has a history of engaging taxpayers and dragging out investigations until the taxpayer runs out of money. An audit can make things extremely hot for you, especially with California in such perilous budgetary straits.
Los Angeles Tax Refund Lawyer
The only defense against investigation this intense is by careful, patient, thoughtful analysis and response to the FTB. When the FTB feels that the taxpayer will respond thoughtfully and will not capitulate, and is buttressed by the facts, and by the law, there is the best chance to get a decent result. Great results are few and far between with the FTB. There is no alternative but to push back with more persuasive facts, and deeper knowledge of the law. However, in some situations the best approach is to know when to drag out the matter so that the IRS statute of limitations expires, and then stop the bleeding.
$100,000,000
Givner & Kaye has represented taxpayers whom the FTB is trying to assess with $100,000,000 in taxable income. These audits and protests have gone on for 4 to 5 years. The FTB has spent so much time and money on these matters, and collected so little, that the State of California passed a special program for all such taxpayers. As a result, these matters have all been favorably resolved, with the IRS statute of limitations expired, the Federal tax savings assured, and the taxpayers paying a net tax of 6 cents on the dollar.
California Franchise Tax Board Audits
Givner & Kaye makes the same journey at the state level that we make with the IRS. We begin at the audit level, giving investigators the complete picture of your tax behaviors.
California Franchise Tax Board Protests & Settlements
If the audit is going nowhere, we opt to terminate the audit and take your case to FTB Protests & Settlements, where the FTB personnel have broader latitude to negotiate a compromise.
State Board of Equalization Hearings
Next in the chain of tax venues is the State Board of Equalization Hearings, which is roughly analogous to the U.S. Tax Court.
California State Tax Refund Litigation
Very often the solution is to pay your taxes at the level of the State Board of Equalization Hearings, and to proceed from there to what was probably your best chance of resolution all along, California State Tax Refund Litigation. At this level, occurring in California's Superior Courts, you are no longer dealing with the FTB, and the likelihood of being fairly and respectfully heard is at its greatest.
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It is a long journey, taking years, and it is expensive. But if your tax problems qualify as major, the journey is well worth the effort. Eventually it will end, with a strong chance of saving millions of dollars.
Call or e-mail California Franchise Tax Board (CFTB) attorneys Bruce Givner and Owen Kaye. Let us put an end to your California tax problems.
