Tax Resolution Center
(408) 287-1888 Free Consultation
Tax Attorneys · Enrolled Agents · San Jose, CA

Owe the IRS or California? We've Saved Clients Over $1.4M in Tax Liabilities.

A 25-year tax attorney and a 40-year Enrolled Agent fight for businesses and individuals in IRS audits, CDTFA sales tax cases, EDD payroll disputes, and US Tax Court — without judgment, and with a strategy that actually works.

Get a Free Case Review → (408) 287-1888
65+ years combined experience Free 30-minute consultation
[Image: confident attorney + EA reviewing case documents]
$1.4M+Saved for Clients
65+Years Experience
FreeInitial Consultation
If any of this sounds familiar…

You're not alone — and you don't have to face the IRS by yourself.

An IRS notice in the mailbox. A sales tax auditor asking for three years of POS data. A wage garnishment letter from your employer. These are stressful — but they are solvable when you have the right team.

If you run a restaurant in California…

A CDTFA audit isn't a verdict. It's a methodology problem we can defeat.

Single-day site tests. Cherry-picked credit-card ratios. Extrapolations that turn a $5K observation into a $500K assessment. We've defended Bay Area restaurants against exactly this — and won at Appeals Bureau.

If you owe more than you can pay…

You probably have more options than the IRS told you about.

Offer in Compromise. Currently Not Collectible. Installment agreements. Penalty abatement. The IRS rejects two-thirds of OICs because they're structured wrong. We structure ours to be accepted.

If your auditor said "the books are inadequate"…

That sentence is the beginning of a strategy — not the end of your case.

We've defended audits where the auditor skipped required reasonableness checks, ignored bank-deposit analysis, and applied arbitrary statistical samples. Appeals Bureau accepts these arguments. US Tax Court does too.

If they're already taking your paycheck…

30 days. A Collection Due Process hearing. We can stop the bleeding.

Letter 1058. LT11. Bank levy. Wage garnishment. Each has a deadline and a defense. We file CDP appeals, negotiate releases, and put currently-not-collectible status in place so the IRS stops taking your money this month.

The government can be wrong

⚖️ An audit assessment is not always correct.

Auditors make assumptions — and those assumptions can be challenged. A well-prepared appeal may reduce or even eliminate the proposed tax liability. Many business owners don't realize they have options.

Sales tax audit

🧾 One sales tax mistake can trigger years of liability.

A small reporting error can grow into a large assessment when projected over multiple years. Understanding the audit methodology is often the key to defending your business.

CDTFA appeals

⚖️ You may have the right to appeal.

A proposed assessment is not always the final result. Deadlines matter. Evidence matters. Strategy matters. The earlier you act, the more options you have.

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IRS Audit or Notice

CP-2000, CP-504, Letter 1058 — every IRS letter has a deadline. Missing it can multiply what you owe.

CDTFA Sales Tax Audit

Restaurants and liquor stores get singled out for sampling-based audits. Without statistical defense, you pay full extrapolation.

Back Taxes & Collections

Wage garnishment, bank levies, liens. We can negotiate Offer in Compromise, installment plans, or hardship status.

What We Do

Specialized representation across every stage of a tax dispute.

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IRS Audit Representation

Income tax, payroll, and information-return audits — defended end-to-end. We work directly with revenue agents so you don't have to.

See how we defend audits →

CDTFA Sales Tax Defense

Our specialty. Statistical modeling defeats sampling-based extrapolations that catch most practitioners off-guard. Saved one client $500K.

CDTFA audit playbook →

Offer in Compromise (OIC)

Settle tax debt for less than you owe based on your ability to pay. We structure the offer the IRS and FTB are most likely to accept.

See OIC eligibility →

Stop Wage Garnishment & Bank Levy

Collection Due Process hearings, currently-not-collectible status, asset protection. We move fast when your paycheck or bank account is at risk.

Emergency collection help →
Industries We Defend

Is your business being audited?

California targets cash-intensive small businesses. If you're in one of these industries, here's what auditors look for — and how a proper defense begins.

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Nail Salon Audit

Why are nail salons being audited?

Many California nail salons are facing increased scrutiny from the IRS, CDTFA, and EDD. A proper defense starts with understanding how auditors build their case.

How we defend nail salons →

Common audit issues

  • Cash transactions & underreported sales
  • Worker classification (employee vs. 1099)
  • Sales tax on products vs. services
  • Incomplete recordkeeping
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Restaurant Audit

Why are restaurants singled out?

CDTFA runs sampling-based audits on restaurants — a single-day observation can become a multi-year, six-figure assessment. We defeat the methodology, not just the math.

Read a real restaurant case →

Common audit issues

  • Credit-card-to-cash ratio extrapolation
  • POS / Z-tape data demands
  • Comps, voids, and spillage
  • Tip allocation & payroll
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Liquor Store Audit

Liquor stores: a CDTFA favorite.

Markup analysis and pour-cost assumptions are routinely used to inflate assessments. The right statistical rebuttal can cut the number dramatically.

CDTFA defense for liquor stores →

Common audit issues

  • Markup & margin extrapolation
  • Inventory shrinkage assumptions
  • Exempt vs. taxable item mix
  • ABC license interplay
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Convenience Store & Market Audit

Markets & convenience stores.

High-volume, mixed taxable/exempt inventory makes these stores a sampling-audit target. We rebuild the numbers from your real data.

Defend my store →

Common audit issues

  • EBT / exempt food vs. taxable mix
  • Cigarette & lottery reporting
  • Cash sales reconstruction
  • Supplier purchase markups
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Retail & Other Small Business

Any cash-intensive business.

Retail shops, salons, auto services, and other small businesses face the same audit playbook. If you've received a notice, the clock is already running.

Get a free case review →

Common audit issues

  • Resale certificate disputes
  • Exempt-sale documentation
  • Service-vs-tangible classification
  • Recordkeeping gaps
Notable Successes

Real results, real dollars saved.

Below is a sample of recent wins. Client names are kept confidential — outcomes are documented.

[CDTFA case visual]
CDTFA Appeals Bureau

Multi-Location Restaurant — $5.7M Extrapolation Challenge

$50K penalty struck
+ reaudit ordered

CDTFA auditor extrapolated a single-day credit-card-ratio site test across a 3-year audit period to assert $5.7M in unreported sales — $507K in tax plus a $50K negligence penalty. On appeal we secured a reaudit using the proper ratio applied uniformly (plus a 5% tip allowance), and the negligence penalty was deleted entirely.

[Airplane case visual]
CDTFA Sales Tax

Airplane Purchase Use Tax

$700K saved

Successfully defended a sales tax audit on an airplane purchase, eliminating the $700K assessed liability.

[S-Corp case visual]
IRS Appeals

S-Corp Basis Restoration

$6.0M basis restored

Appeals Officer accepted back-to-back loans totaling $6.0M, restoring shareholder basis and unlocking previously disallowed losses.

See All Case Results →
Featured Analysis

How a one-day audit observation became a $500,000 CDTFA assessment.

An anonymized walkthrough of a real California Department of Tax and Fee Administration audit — drawn from a published Appeals Bureau decision. A multi-location restaurant operator received a $507,409 sales tax assessment built entirely on a single-day site test and a "credit-card ratio" extrapolated across three years.

The article breaks down the five methodology errors that CDTFA's own audit manual prohibits — and the framework we use to defeat sampling-based extrapolations at appeal. Required reading for any California restaurant or liquor-store owner facing a CDTFA audit.

Read the full analysis →
CDTFA · Featured Case

Anatomy of a CDTFA Restaurant Audit

How a single-day site test becomes a $507,000 assessment — and the 5 methodology errors restaurant owners can use to fight back on appeal.

14 min read · By Jonathan C. Do, Esq. & Tuan Phan, EA →
A clear path forward

How working with us works

Four steps from panic to resolution — you'll always know what's next.

  1. 1

    Free case review

    Tell us what you're facing in a 30-minute call. We assess deadlines, exposure, and options — no obligation.

  2. 2

    Strategy & engagement

    We map a defense: documents to gather, deadlines to protect, and the strongest legal position for your facts.

  3. 3

    We deal with the agency

    We represent you directly with the IRS, CDTFA, or EDD. You stop fielding the calls and letters.

  4. 4

    Resolution

    Reduced assessment, settled debt, released levy, or accepted offer — we push for the best outcome and close it out.

In Our Clients' Words

"They reduced our audit assessment by approximately $500K."

Tax Resolution Center's combination of legal expertise and statistical-modeling depth is what made the difference. Most general practitioners can't defend a CDTFA sampling audit. They can.

Despite our business's strong success, we were selected for a sales tax audit by CDTFA. Mr. Do and Mr. Phan developed complex statistical models and analyses to support our tax position, successfully appealing the audit assessment. As a result, they were able to reduce the audit assessment by approximately $500K. — C.G., Restaurant Owner
Your Team

Two specialists, one mission: fight for your best outcome.

[Attorney photo — Jonathan]
Tax Attorney · Esq.

Jonathan C. Do, Esq.

25+ years representing Silicon Valley businesses in commercial law, taxation, partnership, corporation, and real estate matters. Lead counsel on US Tax Court petitions and IRS appeals.

Full bio →
[Attorney photo — Tuan]
Enrolled Agent · MS Tax · MA Pro Acct

Tuan Phan, EA

40+ years representing taxpayers before the IRS. Specializes in complex audits, statistical analysis for CDTFA sales tax defense, and tax controversy resolution.

Full bio →
Free Resource

Just got an IRS notice? Don't panic. Download our free 7-step guide.

"What to Do When You Get an IRS Notice" — a plain-English guide written by our team. Covers the most common notices (CP-2000, CP-504, Letter 1058), what each one means, and exactly what to do in the first 30 days.

  • Decode the 8 most common IRS notices
  • Critical deadlines you cannot miss
  • When to handle it yourself vs. get help
  • What the IRS won't tell you about your options

Get the Free Guide + Case Review

We'll email the PDF immediately and follow up to offer a free 30-minute case review. No obligation, no sales pitch.

Your information stays confidential. We don't sell or share contact data.

Call Us

(408) 287-1888
or (408) 393-6142

Visit Us

621 Tully Road, Suite 106
San Jose, CA 95111

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Email

taxresolutionllc@gmail.com

Call (408) 287-1888 — Free Consultation