1. The Tax Notice Determines the Agency and Review Process
The notice identifies the agency and tax period. Its legal effect determines the available response procedures and filing deadlines.
Federal and State Notices Require Different Responses
The IRS handles federal income and employment taxes. California's Franchise Tax Board (FTB) handles income and franchise taxes, the California Department of Tax and Fee Administration (CDTFA) handles sales and use taxes, and the Employment Development Department (EDD) administers state payroll taxes. A records request is not a final assessment. An attorney must identify the notice's legal effect before submitting evidence or contesting collection.
County Property Assessments Differ from City Business Taxes
The Los Angeles County Assessor values property, the Assessment Appeals Board hears valuation disputes, and the Treasurer and Tax Collector issues bills. The City of Los Angeles Office of Finance administers business taxes, including qualifying activities by firms outside city limits. Property tax assessment disputes involve different evidence and procedures from city business tax assessments.
2. Tax Legal Services Address Assessments, Debt, and Business Exposure
Representation may address a proposed assessment, collection action, or potential personal liability. Each requires a separate analysis.
Examine Audit Adjustments and Supporting Evidence
An audit may dispute reported income, deductions, or transaction treatment. An attorney can test the agency's calculation against records and law. The scope of IRS audit defense changes when an examination reaches the statutory notice stage. An error alone does not prove fraud.
Evaluate Liens, Levies, and Payment Alternatives
The IRS may file a notice of federal tax lien or pursue a levy on collectible tax debt, subject to applicable notice and review rights. Eligible taxpayers can request installment terms, an offer in compromise, or collection review. The IRS weighs income, expenses, and asset equity when evaluating an offer. Tax debt resolution requires examining the balance, collection stage, and payment capacity.
Test Business Taxes and Personal Liability Separately
Sales tax cases may involve receipts, resale certificates, and exemptions. Under 26 U.S.C. § 6672, a responsible person who willfully fails to collect or pay over federal trust fund taxes may face personal liability. A title or ownership interest alone does not establish responsibility. Payment authority and knowledge matter.
3. Tax Appeals Have Distinct Filing Deadlines and Forums
These deadlines apply to particular notices. An informal agency discussion does not replace the required filing.
Federal, State, and Local Tax Notices Set Different Clocks
A federal deficiency notice may open Tax Court review before payment. California tax notices generally require an agency protest or petition first.
| Notice or Dispute | General Filing Period | Initial Forum |
|---|---|---|
| IRS statutory notice of deficiency | 90 days to petition | U.S. Tax Court |
| FTB Notice of Proposed Assessment | 60 days to protest | FTB |
| FTB Notice of Action on a protest | 30 days to appeal | Office of Tax Appeals |
| CDTFA sales tax Notice of Determination | 30 days to petition | CDTFA |
| LA County regular property assessment | July 2 to November 30 | Assessment Appeals Board |
| LA City business tax assessment | 45 days after service to request a hearing | City Office of Finance |
IRS statutory notice of deficiency
- General Filing Period90 days to petition
- Initial ForumU.S. Tax Court
FTB Notice of Proposed Assessment
- General Filing Period60 days to protest
- Initial ForumFTB
FTB Notice of Action on a protest
- General Filing Period30 days to appeal
- Initial ForumOffice of Tax Appeals
CDTFA sales tax Notice of Determination
- General Filing Period30 days to petition
- Initial ForumCDTFA
LA County regular property assessment
- General Filing PeriodJuly 2 to November 30
- Initial ForumAssessment Appeals Board
LA City business tax assessment
- General Filing Period45 days after service to request a hearing
- Initial ForumCity Office of Finance
Statutory overseas rules may extend an IRS deficiency petition period to 150 days. Other FTB and CDTFA notices can have different deadlines. Check the specific document.
Local Appeals and Further Review Follow Separate Routes
County supplemental assessments generally have a separate 60-day appeal window. Under Los Angeles Municipal Code § 21.16, city business tax assessments first go to an Assessment Review Officer. A Board of Review request generally follows within 45 days after service of that officer's decision. A CDTFA Appeals Bureau decision may be appealed to the state Office of Tax Appeals, generally within 30 days. After a filing deadline passes, any refund or other remedy requires separate eligibility review.
4. A Tax Case Review Depends on Records and Procedural Choices
Each contested amount needs a tax period, supporting record, and legal basis. Evidence gathering must not displace deadline compliance.
Match the Notice to Returns and Transaction Records
Preserve notices, envelopes, returns, transcripts, payments, and audit reports. Business cases may require receipts, bank deposits, invoices, and payroll records. A deposit may be a loan or transfer rather than taxable revenue. The business tax lawyer article covers IRS reconciliation; this review selects the appropriate protest, appeal, or collection route.
Avoid Filing Errors and Unintended Disclosures
An examiner's discussion does not extend a Tax Court petition deadline. A petition mailed to the IRS may not qualify as a filing with the court. A Los Angeles County assessment appeal does not suspend property tax payment obligations, and an FTB protest does not stop interest. Keep filing receipts and review privileged communications before disclosure.
11 Nov, 2026
