California Tax Controversy

California tax law is complicated. Its taxing agencies are known as the toughest of any state-even tougher than the IRS. The tax system is also byzantine and has recently undergone major changes. We can help maximize your chance of favorably resolving a significant matter in this environment because our firm checks all the boxes:

Focus on California taxation

Technical expertise

Boots on the ground in California

Government experience

Strong professional relationships with key government officials

Deep knowledge of the process

Successful track record at the administrative level

Successful track record in court

Whether you want to litigate or settle, you should choose a firm that the agencies know can go the distance. Firms like ours with a reputation for winning at the administrative level and in court-and holding the agencies accountable- get the best deals for their clients. Firms that are known to always settle do not. It is just that simple.

Franchise and Income Taxes: Franchise Tax Board (FTB)

Dakessian Law can handle FTB audits, protests, settlements, closing agreements, stipulations, and administrative appeals (before the OTA) as well as trial and appellate litigation. Our firm can help with any FTB matter, including, but not limited to the following:

  • Corporate franchise tax
  • Corporate income tax
  • Unitary/nonunitary issues
  • Allocation and Apportionment issues
  • Business/nonbusiness issues
  • Credits and incentives
  • Tax Shelters
  • Abusive tax avoidance transactions
  • Noneconomic Substance Transactions (NEST)
  • Commercial Domicile
  • Flow-through entities
  • Personal income tax
  • Residency
  • Sourcing of income
  • Commerce Clause
  • Other Federal constitutional issues
  • Federal preemption
  • State constitutional issues
  • Regulations
  • Penalty abatement
  • Interest abatement
  • Attorneys’ fees

Sales and Business Taxes: California Department of Tax and Fee Administration (CDTFA)

Dakessian Law can handle audits, appeals conferences, settlements, and litigation before trial and appellate courts. Our firm can help with any sales or business tax matters, including, but not limited to:

  • Resale exemptions
  • Drop shipments
  • Manufacturing exemption
  • Other exemption issues
  • Gross receipts issues
  • Regulatory issues
  • Use tax issues
  • Local tax reallocation
  • Bradley-Burns Local Sales and Use Tax Law
  • Service enterprises
  • Leases
  • Technology transfer agreements
  • Taxability of software
  • Reliance on prior audit advice
  • Sampling issues
  • Other taxes and fees administered by CDTFA
  • Commerce Clause
  • Other constitutional issues
  • Penalty abatement
  • Interest abatement
  • Attorneys’ Fees

Local Taxes: License Taxes, Property Taxes and Miscellaneous Taxes and Fees

Our firm handles audits, administrative protests and appeals, settlements, and litigation before trial and appellate courts. Our firm can help with any local tax matters, including, but not limited to:

  • Allocation and apportionment
  • Sourcing of receipts
  • Classification
  • Gross receipts issues
  • Local tax reallocation
  • Bradley-Burns Local Sales and Use Tax Law
  • State constitutional challenges
  • State preemption
  • Federal constitutional challenges
  • Federal preemption
  • Regulatory matters
  • Penalty abatement
  • Interest abatement
  • Attorneys’ Fees

Property and Excise Taxes: State Board of Equalization (BOE)

Dakessian Law can handle audits, administrative protests, settlements, and litigation before trial and appellate courts. Our firm can help with any State Board of Equalization matter, including, but not limited to:

  • State-assessed property tax
  • Insurance tax appeals
  • Alcohol beverage tax appeals
  • Penalty abatement
  • Interest abatement
  • Attorneys’ Fees

Payroll Tax: Employment Development Department (EDD)

Our firm handles audits, administrative protests and appeals, settlements, and litigation before trial and appellate courts. Our firm can help with any local tax matters, including, but not limited to:

  • Employee/independent contractor
  • Penalty abatement
  • Interest abatement
  • Attorneys’ Fees