The firm has substantial experience with representing companies, partnership, trusts and individuals before the California Franchise Tax Board. The firm is uniquely located in the San Francisco Bay Area, and our attorneys often make appearances at hearings before the California Franchise Tax Board in Sacramento. The founder of the firm, Steven L. Walker, worked at the California Franchise Tax Board, and our lawyers understand the unique procedural rules involved in representing clients before the state taxing agencies. A sampling of our work includes:

• Representing clients during audit including reviewing audit plans, attending opening conferences, responding to information document requests, managing fact and information gathering, and resolving issues at the audit level whenever possible.

• Preparing and filing written protest letters in response to a Notice of Proposed Assessment and representing clients at protest hearings.

• Negotiating settlements of civil tax matters with the Settlement Bureau of the California Franchise Tax Board.

• Appealing an adverse Franchise Tax Board decision to the State Board of Equalization.

California Residence Disputes

The firm represents individuals who claim that they are not residents of the state of California and are therefore not subject to tax under California income tax law. We handle residency audits, protests, and settlements before the Franchise Tax Board Settlement Bureau. We also advise individuals who seek to leave California and move to a different state.

The Office of Tax Appeals (OTA)

We handle the representation of taxpayers who are involved in administrative appeals from the California Franchise Tax Board (FTB) or the California Department of Tax and Fee Administration (CDTFA).  A taxpayer may file an appeal once the agency issues a Notice of Action or Appeals Bureau Decision with an “appeal-by” date.

The Office of Tax Appeals (OTA) is an independent and impartial appeals body created by the Taxpayer Transparency and Fairness Act of 2017. The office was established to hear appeals from California taxpayers regarding various taxes and fees administered by the California Department of Tax and Fee Administration and the Franchise Tax Board.

Tax disputes involving personal income, corporate franchise and income, sales and use, excise and other taxes and fees are decided by a three-member panel of Administrative Law Judges, each of whom is an expert in tax law. The office is independent of the state’s tax agencies. Appeals are heard in Sacramento, Fresno and Los Angeles.

The Office of Tax Appeals is the successor in interest to the State Board of Equalization (BOE).

Annual Sacramento Delegation

Our attorneys stay informed and connected with the state taxing agencies through their involvement with the California State Bar Taxation Section. The firm has presented papers on topics of concern to high-ranking officials of the Board of Equalization, Franchise Tax Board, and the Legislative Staff at the Capital Building in Sacramento as part of the Annual Sacramento Delegation with the State bar.