IRS and Franchise Tax Board Audits and Appeals

• Have you received notice of an Internal Revenue Service (IRS), Franchise Tax Board (FTB) or State Board of Equalization (SBE) audit?
• Are you in the middle of a difficult audit?
• Do you want to get to the IRS Appeals Division? Or the FTB settlement unit? Or the FTB Protest Unit? Or to an SBE hearing?
• Are you considering filing a petition in the US Tax Court to get to IRS appeals?
• Did your IRS audit, FTB or SBE audit end badly?
• Do you have offshore accounts but have, so far, failed to pay taxes and disclose them? Have you unfiled FBARs (TD F 90-22.1)?
• Do you have assets sufficient to pay your taxes but you don’t have the liquidity? Do you need to enter into an installment agreement? An offer in compromise (OIC)? Do you need to file for Innocent Spouse relief?
• Do you not have sufficient assets to pay your taxes but you do have some ability to make payments?
• Are you a business owner and need to settle back payroll tax liabilities? Are you facing a trust fund liability (IRS Form 941)?
• Have you filed late tax returns? IRC Section 6501.
• Have you failed to file or pay your federal income tax returns for any year?
• Do you think there is a mistake on a filed tax return?
• Have you been charged with a Tax Preparer Penalty, Accuracy Related Penalty, or another kind of IRS penalty?
• Have you signed an audit extension with the IRS?
• Did you go to the IRS Appeals Division after an IRS audit, but received an unattractive offer?
• Do wish to pay the tax and sue for a refund in the U.S. District Court or the Court of Federal Claims?
• Do you need to pay your state tax, file for a refund and then, when the FTB does not respond, file a suit in Superior Court for a refund?

If you answered “Yes!” to any of these questions, then you need to contact the experienced tax law attorneyss at Givner & Kaye immediately for guidance.


"We represent clients in audits and appeals before the IRS; audits, protests and settlements before the California Franchise Tax Board; and hearings before the California State Board of Equalization."

These matters include:


  • Income audits and appeals, tax disputes, deficiencies, penalties and tax shelters.
  • Offers in compromise, installment payments, and innocent spouse relief
  • OVDI (Offshore Voluntary Disclosure Initiative)
  • Retirement plan audits, prohibited transactions penalties and disqualification issues
  • Preparer penalties
  • Estate and gift tax audits, appeals, penalties, and litigation in Tax Court and refund litigation
  • Tax Court litigation and refund litigation in Federal District Court and Court of Federal Claims
  • Franchise Tax Board Audits, Settlements, Protests, State Board of Equalization Hearings



"When necessary, the experienced tax attorneys of Givner & Kaye will help the clients pursue their claims to the United States Tax Court, the United States District Court, the United States Court of Claims and L.A. Superior Court."

Our firm typically collaborates with clients’ CPAs on these matters until a tax attorney’s direct involvement becomes necessary.

Read the client and professional testimonials on Givner & Kaye to see how our experienced tax attorneys, estate planning and asset protection professionals can help you to save money on taxes, make more money and gain peace of mind over all estate planning, tax planning, tax litigation and asset protection matters.