Tax - Federal, State, And Local
We provide tax planning and tax controversy resolution services. Two of our lawyers are certified as taxation specialists by the State Bar of California Board of Legal Specialization.
- Federal, California and local tax planning for new, emerging and established businesses.
- Federal and California tax planning for business transactions including mergers, acquisitions, reorganizations and dispositions.
- Federal and California civil income tax controversy resolution at all levels, from audit to appeals to litigation.
- Estate and gift tax planning.
- Estate and gift tax controversy resolution at all levels, from audit to appeals to litigation.
- Counsel to individuals, corporations, partnerships, limited liability companies, trusts and nonprofit organizations concerning a wide range of income, estate, gift, property, sales and use and franchise tax matters.
- Our lawyers have been successful counsel in Zaninovich v. Commissioner (9th Cir. 1980) 616 F.2d 429 [cash basis farmer's payment of farm rental attributable to following tax year held deductible in the year paid]; Rojas v. Commissioner (9th Cir. 1990) 901 F.2d 801 [cash basis corporation's crop costs deductible in year of its liquidation even though crops had not been harvested]; Giannini Packing Corporation v. Commissioner (1984) 83 T.C. 526 [agricultural cold storage facility held eligible for the investment tax credit]; and Estate of Frazier v. Commissioner (9th Cir. 2003) 2003-2 U.S.T.C. ¶60,473 [almond and walnut processing facilities built at the tenant’s cost on leased property were not includable in the landlord’s estate for estate tax purposes].
- Litigation support through expert witness engagements and other consultations with trial counsel.
We recently settled an Internal Revenue Service appeal, for no liability to the taxpayer, of an auditor’s determination that large losses from a horse farming operation were nondeductible “hobby” losses. We also favorably settled an Internal Revenue Service audit attempting to disallow farming losses as "passive activity losses," favorably settled a United States Tax Court petition concerning income tax characterization of the use of an aircraft, and favorably settled an Internal Revenue Service attempt to collect substantial compliance-related penalties from a nonprofit organization.