Represent businesses and taxpayers in all IRS income tax audits, appeals, and U.S. tax court, CDTFA sales tax audits and appeals, EDD payroll taxes audits, and various tax collection appeals
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(408) 287-1888
OUR MISSION
We are highly skilled in helping our tax clients to resolve their tax dilemma. It's a highly charged, stressful, and difficult time under the scrutiny of the tax authorities like the IRS and the CA Department of Tax & Fee Administration (CDTFA). Tax problems can be devastating and very difficult to overcome without having the right tax expert on your side. Our mission is to represent our clients both diligently and effectively to secure optimal results. We will "fight for you."
OUR SERVICES
Audit Representation
Represent restaurants, liquor stores, and taxpayers to defend IRS audits of income tax, California Department of Tax and Fee Administration audits of sales tax, and EDD audits of payrolls taxes. Work with IRS revenue agents and tax auditor to resolve audit issues and reduce tax liabilities.
Appeals
Represent taxpayers to appeal unagreed income tax audit assessments to the IRS Office of Appeals. Appeal collection cases involving Collection Due Process, Offer in Compromise, Trust Fund Recovery Penalties, etc. Appeal sale tax audit assessments by CDTFA to both Petition Section and under CDTFA Settlement Program.
Petition to US Tax Court
Stop Collections and Protect Assets
Experienced tax attorney to represent clients before the US Tax Court. File petitions and negotiate with the IRS in pre-trial settlement to settle cases without going to trial.
Represent taxpayers in Collection Due Process Hearing and stop collection process such as wage garnishment and bank levy and help clients to protect their assets.
Tax Reliefs and Offer-in-Compromise (OIC)
Complex Corporate Tax Controversies and International Taxation
Assist clients to settle tax debts for less than the full amount of income tax and sales tax owed based on the clients’ ability to pay, income, expenses and asset equity. Work with the tax authorities like IRS, Franchise Tax Board, and California Department of Tax and Fee Administration to settle the tax debts at minimum qualified amounts.
Assist corporate taxpayers to structure qualified R&D credit, transfer price, cost sharing, management service allocation, controlled foreign corporation, California water-edge election, and obtain private ruling letter from the IRS, and more.
Expert Testimonies
Special Services
Provide expert declarations and develop statistical evidence and quantitative models to support taxpayer’s position against erroneous statistical samplings and extrapolations used in sales tax audits.
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Employee retention credit (ERC)- analysis & defense
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Tax model development (R&D, transfer price, cost sharing, etc.)
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Tax research
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Tax preparation services
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Real estate taxation and more
NOTABLE SUCCESES
IRS Office of Appeals
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During an IRS audit, an S-Corp shareholder's basis was disallowed, resulting in the rejection of a significant deductible loss. On appeals, the Appeals Officer accepted back-to-back loans totaling $6.0M, which increased the shareholder's basis and enabled the shareholder to deduct the distributive losses.
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IRS Office of Appeals agreed that $320K was not distributive dividend thus saving the taxpayer over $100K of tax liability.
U.S. Tax Court Pre-trial Settlements
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ESRP liability of $80K reduced to zero in pre-trial settlement.
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1099 income resulting $130K tax liability reduced to zero in pre-trial settlement.
Sales Tax Audit by CDTFA
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Successfully defended a sales tax audit on an airplane purchase, saving the client $700K in sales tax.
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Successfully appealed a sales tax audit assessment by developing statistical models and analysis to support the client's tax position. The models employed statistical sampling of credit card ratios in the extrapolation methodology, resulting in a savings of approximately $500K in assessed tax liability.
OUR BUSINESS APPROACH
We take a collaborative approach when working with tax authorities during audit representation, focusing on a positive, team-oriented relationship rather than an adversarial stance. To advance our clients' interests, we concentrate on gathering strong substantiation for their deductions, securing evidence that supports their tax positions, and employing alternative analytical methods to gain agreement from the auditors, revenue agents, appeals officers, and their superiors; ultimately achieving the best possible audit outcomes for our clients.
TAX PROFESSIONALS
JONATHAN C. DO, ESQ.
Providing legal representation and services for all types of businesses throughout the Silicon Valley Area for over 25 years. Expertise in commercial law, business transactions, taxation, partnership, corporation, real estate, and landlord-tenant issues.
TUAN PHAN, EA, MS (Tax), MA (Professional Accounting)
Enrolled to Practice Before the IRS. Licensed to represent taxpayers in 50 states and has over 40 years of experience helping clients in all aspects of complex tax disputes and controversies, and audit representation. Serving as a tax advisor to several CPA/EA offices, real estate investors, and senior executives in Silicon Valley.
OUR ADDRESS
​Address: 621 Tully Road, Suite 106, San Jose, CA 95111
Email: taxresolutioncenterllc@gmail.com
Tel: 408.287.1888 & 408.393.6142