Tax Controversy
for Businesses

The Law Office of Pietro Canestrelli represents clients before federal and California state taxing authorities, with the objective of resolving disputes prior to litigation. At times, litigation is unavoidable or in the client’s best interest. We have substantial experience litigating tax cases across the country in state and federal courts, including the U.S. Tax Court, U.S. District Courts and U.S. Nineth Circuit Courts of Appeals. We regularly represent businesses in the following types of cases.

Assessments

Income Tax Disputes

Small businesses are frequently the target of income audits by the IRS and the California Franchise Tax Board. The Law Office of Pietro Canestrelli represents the taxpayer from the initial audit through the appeals process and continuing into litigation in the U.S. Tax Court as well as the California Office of Tax Appeal. Attorney Pietro Canestrelli has represented hundreds of taxpayers before the U.S. Tax Court and hundreds more before the IRS Appeals division in income tax disputes and has reduced the amount owed by his clients by millions of dollars.

Taxpayers are often scared and confused by the income tax audit process.  The taxpayer is at a disadvantage because the asymmetry of knowledge and is frequently shocked by the audit results.  Taxpayers would do well to bring in experienced representation as early as possible.

Sales Tax Disputes

The California Department of Tax and Fees Administration conducts sales and use tax audits on businesses. Many businesses are unaware of the rules for selling tangible personal property and buying out of state products for use in California.   Attorney Pietro Canestrelli has represented many taxpayers before the CDTFA in sales and use tax disputes.

Tax-Exempt Disputes

Tax-exempt non-profit organization are also subject to IRS audits to determine if they have violated any of the many tax-exempt rules of the Internal Revenue Code. The Law Office of Pietro Canestrelli has represented many tax-exempt entities before the IRS to keep their tax-exempt status and avoiding penalties.

Employment Tax Disputes

IRS and the California Employment Development audit taxpayers employment tax returns or reclassify independent contractors as employees imposing employments taxes and penalties. Attorney Pietro Canestrelli has represented many taxpayers before these taxing authorities reducing taxes and penalties.

The impact in California of AB 5 and the ever-changing rules on who is and who is not an employee is a pitfall for business.  Businesses should consult with tax experts preferably before these are audited to determine if they are in compliance with the latest California rules.

Have you received a notice of assessment? Contact our office today for guidance on your next steps. Call (951) 319-7674

Collections

Tax Collection Disputes

Sometimes taxpayers do not timely appeal their audits or the amount owed is undisputed. The Law Office of Pietro Canestrelli provides clients with options in these situations including Collection Due Process (CDP) request, Installment Agreement, and Offer in Compromise request

Non-Controversy Procedures

The Law Office of Pietro Canestrelli also specializes in providing taxpayers with expert tax guidance when there is no current controversy. These services include Tax Opinion Letters, Private Letter Ruling Requests, Report of Foreign Bank and Financial Accounts (FBAR) and Foreign Account Tax Compliance Act (FATCA) amnesty requests.

Have you received a collections letter from the IRS, FTB, EDD or CDTFA? Call us now for guidance on your next steps. (951) 319-7674