IRS and FTB Controversy
Federal and California tax disputes require disciplined legal judgment. They involve financial exposure, reputational considerations, and structural consequences that extend beyond the immediate adjustment. The Law Office of Daniel Chung represents individuals, businesses, fiduciaries, and high-net-worth taxpayers in complex federal and California tax matters before the Internal Revenue Service and the California Franchise Tax Board, including administrative Appeals proceedings and, when necessary, the United States Tax Court. Daniel Chung previously served as a senior attorney at the IRS Chief Counsel's Office. That experience informs how legal theories are developed internally, how adjustments are framed, and how litigation risk is evaluated. Advocacy is measured, technical, and deliberate. We structure controversies carefully from the outset.
We represent clients in IRS and FTB matters involving audits, examinations, notices of deficiency, proposed assessments, administrative appeals, and tax litigation.
Matters frequently include:
Each matter is evaluated for technical merit, procedural posture, and long-term exposure.
IRS audits of high-income individuals and closely held businesses
Franchise Tax Board audits and residency examinations
Business expense and substantiation disputes
High-income / high-asset taxpayer audits
Legal-fee deductibility disputes
Income reconstruction and unreported income allegations
Constructive dividend and compensation recharacterization issues
Foreign asset reporting and offshore compliance matters
Multi-year and multi-issue examinations
Audit reconsideration and refund claims
Appeals conferences before the IRS Office of Appeals and FTB
IRS & FTB Collections and Tax Debt Resolution
The firm represents taxpayers facing:
Wage garnishments and bank levies
Federal tax liens and state tax liens
Trust fund recovery penalty exposure
Payroll tax liabilities
Filing compliance issues and delinquent return submissions
Resolution strategies may include:
Offers in Compromise
Installment agreements
Partial pay installment agreements
Currently Not Collectible status
Penalty abatement requests
Innocent spouse and equitable relief claims
Representative Matters
Representative federal and California matters include:
Securing six-figure tax liability reductions in contested IRS audit adjustments for high-income taxpayers
Achieving substantial IRS Appeals tax liability relief exceeding $500,000 in a coordinated examination involving an ultra-high-net-worth family.
Negotiating seven-figure Offers in Compromise involving complex asset valuation and collection analysis.
Securing favorable outcomes in California residency and capital gain sourcing disputes before the Franchise Tax Board.
Obtaining full concession of a seven-figure Notice of Deficiency issued to a professional athlete.