Below is a sample of recent wins across IRS appeals, US Tax Court pre-trial settlements, and CDTFA sales tax cases. Client names are confidential; outcomes are documented.
Challenge: IRS auditor disallowed S-Corp shareholder's basis, rejecting a significant deductible loss.
Action: Appealed with documentation of back-to-back loans totaling $6.0M.
Result: Appeals Officer accepted the basis, restoring the deductible loss position.
Challenge: IRS characterized $320K of distributions as taxable dividends.
Action: Presented evidence of non-dividend treatment on appeal.
Result: Appeals Officer agreed $320K was not a distributive dividend — saving the taxpayer over $100K in tax liability.
Challenge: Employer Shared Responsibility Payment of $80K assessed under ACA provisions.
Action: Filed Tax Court petition; negotiated pre-trial settlement with IRS counsel.
Result: Liability reduced to zero.
Challenge: 1099 income misreporting resulted in $130K assessed tax liability.
Action: Tax Court petition with pre-trial settlement negotiation.
Result: Liability reduced to zero in pre-trial settlement.
Challenge: CDTFA assessed use tax on an airplane purchase.
Action: Successfully defended through audit and appeals process.
Result: $700K in proposed sales tax fully eliminated.
Challenge: CDTFA auditor performed a single-day on-premises site test, computed a credit-card ratio from that one day, then extrapolated rotating ratios (33%–41%) across a 3-year audit period to assert $5,682,731 in unreported taxable sales — yielding a $507,409 tax assessment plus a $50,740 negligence penalty.
Action: Submitted appeals brief identifying five specific Audit Manual violations — including failure to perform the required reasonableness check (§0802.70), arbitrary z-tape sample selection, and skipped mark-up and bank-deposit analyses.
Result: Appeals Bureau ordered a full reaudit applying the proper 50.88% ratio uniformly across the period with a 5% tip allowance, and struck the $50,740 negligence penalty entirely.
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.
Since sales tax audits require specialized expertise in statistical modeling — an area most general tax practitioners are unfamiliar with — I highly recommend Mr. Do and Mr. Phan for defending your California sales tax audits and appeals.
Free 30-minute consultation. We'll review your situation and tell you honestly what's possible.