For 25+ years we've represented businesses and individuals in the toughest tax controversies — IRS audits, CDTFA sales tax cases, EDD payroll disputes, and US Tax Court petitions. Our reputation is built on outcomes, not promises.
Tax problems are stressful. The IRS and CDTFA have unlimited time, unlimited resources, and an entire playbook designed to maximize what you owe. Most taxpayers — even successful business owners — try to handle it alone or with a general practitioner, and the result is almost always the same: they pay more than they should.
Our mission is simple: level the playing field. We bring deep tax-controversy expertise, statistical modeling, and decades of experience negotiating with revenue agents, appeals officers, and US Tax Court counsel — so you don't have to face them alone.
We take a collaborative posture with tax authorities. Not because we're soft — but because positive, team-oriented relationships with auditors and appeals officers produce better outcomes for clients than adversarial posturing.
Free consultation: review your notice, gather facts, identify deadlines and exposure.
Build the case. Gather substantiation, develop alternative analyses, model the numbers.
Work directly with revenue agents and appeals officers. Present evidence, argue position, secure agreement.
Settlement, OIC, installment plan, or pre-trial resolution. You sign — and move on with your life.
Jonathan has provided legal representation and services for all types of businesses throughout the Silicon Valley area for over 25 years. His expertise spans commercial law, business transactions, taxation, partnership and corporation matters, real estate, and landlord-tenant law.
As lead counsel on US Tax Court petitions and IRS appeals, Jonathan has successfully resolved disputes ranging from individual income tax matters to multi-million dollar corporate controversies. He represents clients before the IRS Office of Appeals, the US Tax Court, the California Office of Tax Appeals, and CDTFA Petition Section.
Tuan is an Enrolled Agent licensed to represent taxpayers before the IRS. With over 40 years of experience, he serves as a tax advisor to several CPA and EA offices, real estate investors, and senior executives in Silicon Valley.
His specialty — and the firm's competitive moat — is the use of statistical modeling and quantitative analysis to defeat CDTFA sales tax extrapolations. Sampling-based audits are extremely difficult to defend without specialized statistical expertise; Tuan has used credit-card ratio analysis, alternative sampling methodologies, and quantitative substantiation to secure assessment reductions for restaurants, liquor stores, and California businesses.
Most tax practitioners cannot defend a sampling-based CDTFA audit because it requires statistical modeling expertise. We've built models that have reduced assessments by hundreds of thousands of dollars.
Restaurants, liquor stores, real estate investors, and Silicon Valley tech businesses. We know the audit playbooks the IRS and CDTFA use against your industry.
From the first IRS notice all the way to US Tax Court. You don't have to find a new firm at each stage of the dispute.
Free 30-minute consultation. We'll review your notice or audit letter, explain your options, and tell you honestly whether you need us.