Tax Controversy
IRS, Franchise Tax Board, and Board of Equalization disputes — audits, liens, levies, installment agreements, and Offers in Compromise.
When you face the IRS, the FTB, or the BOE, the odds feel stacked against you. Our job is to balance them.
When an individual or business must face the IRS, the California Franchise Tax Board, or the California State Board of Equalization, the odds seem stacked against the taxpayer. Engaging our Palm Desert tax attorneys balances that dispute — often producing a satisfactory settlement without the need of a court trial.
If you have not paid your assessed taxes, the government can deploy what it euphemistically calls 'enforced collection': recording tax liens, levying bank accounts, seizing business or personal assets, and in some cases putting your passport in jeopardy. We help you deal with IRS levies and liens, and explore installment agreements, Offers in Compromise, and penalty abatements.
Many of our clients describe a single, immediate benefit: Sanger & Molever acts as a buffer between you and the IRS — handling every conversation so you stop losing sleep over the next phone call.
Cases We Take On
IRS Audits
Income, estate, and gift tax examinations.
Income, estate, and gift tax examinations. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseFTB & BOE Disputes
California Franchise Tax Board and Board of Equalization.
California Franchise Tax Board and Board of Equalization. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseLiens & Levies
Release, withdrawal, subordination, and discharge.
Release, withdrawal, subordination, and discharge. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseOffers in Compromise
Settle tax debt for less when you qualify.
Settle tax debt for less when you qualify. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseTrust Fund Penalty
100% Penalty defense for unpaid payroll taxes.
100% Penalty defense for unpaid payroll taxes. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseBankruptcy Discharge
Tax-motivated bankruptcy analysis and planning.
Tax-motivated bankruptcy analysis and planning. Our attorneys have decades of experience with these matters and pursue every available remedy — from pre-suit negotiation through trial — to protect your rights and maximize your outcome.
Discuss your caseHow It Works
A clear, four-step path from your first call to the resolution you deserve.
Confidential Intake
We review every notice, letter, and assessment — in detail.
Position the Case
We frame the legal and factual posture before contacting the agency.
Negotiate or Litigate
Most cases settle administratively; we are ready for Tax Court if needed.
Resolution & Compliance
Closing letters, releases, and a forward plan to keep you compliant.
An Advocate Who Treats Your Case Like It's Their Own
Decades of focused experience, transparent communication, and a track record built one client at a time.
Certified Tax Law Specialist
Fewer than one-half of 1% of California attorneys hold this State Bar designation. Mr. Sanger is one of them.
We Are Your Buffer
Stop taking IRS calls yourself. Every communication routes through your attorney — by design.
Deep Tax Knowledge
Two LLM tax degrees and decades of controversy practice — across audits, collections, and appeals.
Move Before Deadlines
Notices of Deficiency, Collection Due Process rights, and statutes of limitations protected from day one.
Settlement-Focused
Most matters resolve administratively — without trial — through experienced negotiation.
Penalty Abatement
First-time and reasonable-cause abatement pursued where the facts support it.
What Tax Controversy Work Covers
From a single audit notice to a multi-year collection matter, we handle the full lifecycle of a tax dispute.
Representation before IRS examiners, FTB auditors, and BOE staff — federal and California.
Liens, levies, wage garnishments, asset seizure, and passport-revocation defense.
Negotiated payment plans calibrated to your actual ability to pay.
Settlement of tax debt for less than the assessed amount when you qualify.
Defense of the Trust Fund Recovery Penalty (the '100% Penalty') and worker-classification disputes.
Analysis of whether bankruptcy can discharge unpaid taxes — including tolling-event review.
What Enforced Collection Actually Looks Like
The IRS's collection arsenal is broader — and quieter — than most taxpayers realize until it lands.
Without the Right Counsel
- Federal tax liens recorded against your home and assets
- Bank-account levies that empty operating accounts overnight
- Wage garnishments that follow you to every employer
- Seizure of business assets, vehicles, and real estate
- Passport certification — restricting international travel
With Us in Your Corner
- Collection Due Process hearings filed before deadlines run
- Lien withdrawal, subordination, or discharge where allowed
- Currently-Not-Collectible status while you reorganize
- Installment agreements and Offers in Compromise pursued in parallel
- Penalty abatement requests built on documented reasonable cause
We handle the IRS so you can run your life.
- We deal directly with revenue agents and revenue officers.
- We organize records, returns, and substantiation.
- You stop dreading the phone — we take the calls.
Planning mode beats repair mode.
- Pre-transaction tax planning that prevents disputes.
- Worker-classification reviews to avoid Trust Fund exposure.
- Recordkeeping protocols audit-tested before they're needed.
Common Questions
Straight answers to what clients ask most. Don't see your question? Reach out — we respond within 24 hours.
When the dispute is administrative or in court, attorney-client privilege and litigation experience matter. We frequently work alongside CPAs — but the legal posture of a controversy belongs in a lawyer's hands.
Yes. The IRS certifies seriously delinquent tax debt to the State Department, which can deny renewal or revoke your passport. We work to decertify before travel is disrupted.
A formal IRS settlement of your tax debt for less than the full balance, based on doubt as to collectability, doubt as to liability, or effective tax administration. Eligibility is fact-driven and we evaluate it candidly.
Most controversies resolve administratively — at audit, in Appeals, or through a Collection Due Process hearing. We prepare every matter as if it could reach court, which strengthens settlement leverage.
Simple correspondence audits resolve in months; field audits and estate-tax exams can take a year or more. We push for the cleanest record and the fastest defensible close.
Sometimes — when the statutory tests are met. The tests are easy to state and hard to apply because of 'tolling events' that extend the lookback periods. We analyze the timeline before any filing.
Personal liability the IRS can assess against responsible persons of a business that failed to remit withheld payroll taxes. Defense often turns on willfulness and responsibility — both of which we challenge on the facts.
Yes — Franchise Tax Board income tax disputes, Board of Equalization sales/use tax matters, and California residency audits are core to our practice.
Talk to an attorney — free consultation, no obligation.
Before your negotiations with the IRS, the IRS's levies and tax liens would have driven us out of business. Thanks to your work, our company is back on its feet.
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Free consultation. No obligation. Confidential.