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    • Anne Wenger
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McLAUGHLIN LEGAL, APC

McLAUGHLIN LEGAL, APCMcLAUGHLIN LEGAL, APCMcLAUGHLIN LEGAL, APC

Tax Appeals Representation by Certified Tax Law Specialists

IRS, FTB, CDTFA, and EDD Appeals – San Diego, California

When a tax audit ends with an unfavorable result, the case is not over. Many taxpayers assume they must simply accept an assessment—but in reality, the appeals process is often where the most favorable resolutions occur.

Why McLaughlin Legal?

At McLaughlin Legal, APC, we represent individuals and businesses in IRS, California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), and Employment Development Department (EDD) appeals. Our firm focuses exclusively on tax law and tax controversy, and our Certified Tax Law Specialist attorneys are experienced in challenging audit determinations, reducing assessments, and resolving disputes before they escalate into enforced collections or litigation.

Contact McLaughlin Legal, APC

Contact Us Today

If you are dealing with unpaid IRS, California FTB, CDTFA, or EDD regarding any appeal of your tax matter, contact McLaughlin Legal, APC today for a free consultation.

Contact

Why the Appeals Stage Is Critically Important

Expert Tax Attorneys at McLaughlin Legal, APC

The appeals process is fundamentally different from an audit. Auditors focus on enforcement; appeals officers are tasked with resolving disputes fairly and efficiently. This makes appeals the best opportunity to:


  • Correct audit errors or overreach
  • Introduce legal and factual arguments
  • Negotiate reductions in tax, penalties, and interest
  • Resolve disputes without court involvement
     

However, appeals are legal proceedings, not informal negotiations. Presenting a weak or disorganized appeal can lock in bad outcomes and eliminate future leverage.

That is why appeals should be handled by experienced tax attorneys, not just accountants.

Expert Tax Help for Individuals and Small Businesses

IRS Appeals Representation

We represent clients in IRS Appeals Office proceedings, including disputes involving:


  • Income tax assessments
  • Disallowed deductions or credits
  • Penalty assessments
  • Business expense and Schedule C disputes
  • Employment tax and payroll tax matters
     

Our attorneys prepare persuasive written protest letters, legal briefs, and supporting documentation designed to withstand scrutiny and drive settlement.

California Franchise Tax Board (FTB) Appeals

FTB appeals often involve complex California-specific issues, such as:


  • Residency and domicile disputes
  • Allocation and apportionment of income
  • Business income recharacterization
  • Pass-through entity audits
     

We represent clients at every stage of the FTB appeals process, including formal protests, settlement discussions, and appeals hearings, with a deep understanding of California tax law and procedure.

CDTFA Appeals (Sales & Use Tax)

CDTFA appeals frequently arise after aggressive audits and estimated assessments. We handle appeals involving:


  • Sales tax audit methodologies
  • Estimated assessments
  • Cash-based business disputes
  • Use tax liabilities
     

Our firm challenges flawed assumptions, reconstructs records where necessary, and negotiates assessments based on defensible legal and factual positions.

EDD Appeals (Payroll & Employment Taxes)

EDD appeals often involve worker classification and payroll reporting disputes that can expose business owners to substantial liability. We represent clients appealing:


  • Independent contractor misclassification findings
  • Payroll tax assessments
  • Wage-based and reporting errors
     

These appeals often overlap with IRS and CDTFA issues, requiring a coordinated, multi-agency strategy—something McLaughlin Legal, APC is uniquely positioned to provide.

Why Choose McLaughlin Legal for a Tax Appeal

Award-Winning Expertise

Comprehensive Tax Law Services

Award-Winning Expertise

Our tax attorneys have been recognized by numerous peer-related publications including Best Lawyers: Ones to Watch and Super Lawyers for outstanding expertise in tax law. With a deep understanding of IRS procedures and tax regulations, our team is well-equipped to handle even the most complex collection issues.

Personalized Approach

Comprehensive Tax Law Services

Award-Winning Expertise

We know that no two clients are the same. We provide personalized legal strategies tailored to your specific financial situation. Our goal is to minimize your financial exposure and stress, guiding you every step of the way.

Proven Track Record

Comprehensive Tax Law Services

Comprehensive Tax Law Services

With years of successful outcomes, our team has a track record of negotiating favorable settlements and resolving disputes with the IRS. We are relentless advocates for our clients, and our results speak for themselves.

Comprehensive Tax Law Services

Comprehensive Tax Law Services

Comprehensive Tax Law Services

As a full-service tax law firm, we offer more than just Offer in Compromise representation. Our legal services include tax dispute resolution, criminal tax defense, and estate planning, providing a holistic approach to your financial and legal needs.

Navigating tax law made easy with McLaughlin Legal, APC - Contact us now!

Our Appeals Strategy: How We Maximize Leverage

Appeals are won through preparation, credibility, and strategic positioning—not emotion or volume.

1. Audit Record Analysis

We dissect the audit file to identify factual errors, legal misapplications, and procedural flaws.

2. Legal Issue Framing

Appeals succeed when issues are framed as legal disputes, not disagreements with an auditor’s judgment.

3. Persuasive Written Advocacy

We prepare detailed protest letters and briefs that clearly articulate the law, facts, and settlement position.

4. Strategic Negotiation

Our attorneys negotiate directly with appeals officers to pursue reduced assessments, penalty abatement, or full reversals where warranted.

5. Litigation Readiness

We prepare every appeal as if it may proceed to court—because credibility increases when the agency knows you are prepared to litigate.

Why Clients Choose McLaughlin Legal, APC for Tax Appeals

Clients trust us with appeals because we offer:


  • Certified Tax Law Specialist attorneys
  • Exclusive focus on tax law and tax controversy
  • Extensive experience with federal and California appeals
  • Strategic, defense-oriented advocacy
  • Clear communication and realistic outcome assessments
     

Appeals are not administrative formalities—they are legal negotiations with long-term financial consequences.

Common Reasons to File a Tax Appeal

Clients often seek appeals representation after:


  • Excessive or inaccurate audit assessments
  • Misapplication of tax law
  • Disallowed deductions without proper analysis
  • Aggressive sales or payroll tax estimates
  • Residency or sourcing disputes
     

If an audit result feels unfair, rushed, or incorrect, an appeal may be the appropriate next step—but deadlines are strict.

Frequently Asked Questions About Tax Appeals

Appeal deadlines are strict and vary by agency. Missing a deadline can forfeit your rights.


Yes. Appeals often result in penalty abatement or reduced assessments.


While not required, appeals are legal proceedings. Attorney representation significantly improves outcomes.


If necessary, we advise clients on litigation options or alternative resolution strategies.


Strategic Appeals Begin with Experienced Counsel

An appeal is often your best—and sometimes last—opportunity to resolve a tax dispute without court involvement. Early involvement of experienced tax attorneys can dramatically change the outcome.


At McLaughlin Legal, APC, we help clients navigate IRS, FTB, CDTFA, and EDD appeals with strategic precision and disciplined advocacy.


Speak with a Certified Tax Law Specialist Today


If you have received an audit assessment or are considering a tax appeal, do not wait. Deadlines move quickly, and leverage decreases with delay.


📞  Call (858) 678-0061 to schedule a free, confidential consultation with a Certified Tax Law Specialist attorney and learn how we can protect your rights and reduce your tax exposure.


Copyright © 2026 McLaughlin Legal, APC - All Rights Reserved.

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