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Tax Attorney in Carson, California

What this page covers

  • Federal IRS, U.S. Tax Court, and California FTB / CDTFA / EDD representation for Carson taxpayers across the 90745 / 90746 / 90747 / 90810 ZIP footprint
  • Port of LA and Port of Long Beach drayage AB 5 reclassification, IRC §7202 trust-fund exposure, and Form 2290 heavy-vehicle-use tax for Carson-based owner-operators
  • Phillips 66 Wilmington Refinery and Marathon Carson Refinery union §401(a) lump-sum distributions, §72(t)(2)(A)(v) age-55 separation, §139 incident-settlement framing, and refinery 1099 turnaround-contractor Schedule C
  • CSU Dominguez Hills faculty CalSTRS §403(b), §117(c) postdoc, and adjunct W-2 versus 1099 misclassification; Dignity Health Sports Park 1099 talent, §3121(q) tip, and §181 entertainment production
  • Filipino-American FBAR / Form 8938 for BPI, BDO, Metrobank, Landbank, Security Bank accounts; Samoan-American FBAR for ANZ Samoa, BSP Samoa, Bank of Hawaii Samoa; Form 3520 inheritance reporting
  • LA County Assessor reassessment, Norwalk Registrar-Recorder NFTL / State Tax Lien recording, and the California 20-year FTB collection statute under R&TC §19255

Federal IRS and California state tax representation for Carson taxpayers — from the Watson Industrial Center and the customs-bonded warehouse cluster along Watson Center Road and 223rd Street, the I-110 / SR-91 / I-405 industrial corridor, the Phillips 66 Wilmington Refinery operators and Marathon Carson Refinery union and 1099 turnaround base, the Cal State Dominguez Hills campus at 1000 E. Victoria Street, the Dignity Health Sports Park at 18400 Avalon Boulevard, the Goodyear Blimp Base at Watson Center, the Carson Plaza shopping district, the Filipino-American and Samoan-American family corridors across 90745, 90746, 90747, and 90810, to the residential blocks of Scottsdale Estates, Carson Park, and the Avalon Boulevard / Main Street commercial spine. Our California Bar-admitted attorneys appear at the IRS Long Beach Taxpayer Assistance Center at 501 W. Ocean Boulevard Suite 2100, the FTB Los Angeles Field Office at 300 S. Spring Street, the CDTFA Cerritos District Office at 12750 Center Court Drive South Suite 400, the LA County Assessor and Assessment Appeals Board at 500 W. Temple Street, the LA County Registrar-Recorder/County Clerk at 12400 Imperial Highway in Norwalk, the LA County Treasurer-Tax Collector at 225 N. Hill Street, and U.S. Tax Court trial sessions at the Edward R. Roybal Federal Building in Los Angeles.

By Parham Khorsandi, Esq. — California Bar #266658. Pepperdine Caruso School of Law, JD 2009. Admitted to practice before the United States Tax Court. Last Reviewed: .

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Carson taxpayers facing IRS collection, FTB Notice of Proposed Assessment, CDTFA audit, EDD AB 5 reclassification, or LA County reassessment

If you live or work in Carson — the Watson Industrial Center along Watson Center Road and 223rd Street, the customs-bonded warehouse cluster feeding the Port of LA and Port of Long Beach, the Phillips 66 Wilmington Refinery and Marathon Carson Refinery operators and contractors, the Cal State Dominguez Hills campus on Victoria Street, the Dignity Health Sports Park at 18400 Avalon Boulevard, the Goodyear Blimp Base at Watson Center, the Carson Plaza and Avalon Boulevard / Main Street retail corridors, the South Coast Botanic Garden corridor, the Filipino-American and Samoan-American family blocks across 90745, 90746, 90747, and 90810, or the Scottsdale Estates and Carson Park residential neighborhoods — you sit in South Bay Los Angeles County between Long Beach to the south, Torrance and Compton to the north, and Wilmington and the Port complex to the west. Carson is a city of roughly 95,000 residents covering 18.7 square miles. The economic mix runs from Port-feeder drayage and trucking, customs and bonded-warehouse operations, two operating petroleum refineries (Phillips 66 Wilmington and Marathon Carson), industrial and aerospace subcontracting, retail and restaurants along Avalon and Carson Street, CSU Dominguez Hills education, MLS / NWSL / U.S. Soccer training at Dignity Health Sports Park, and a heavy Filipino-American and Samoan-American family residential base. This page walks through what Carson representation looks like in practice across the federal IRS and California FTB, CDTFA, EDD, and OTA forums.

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Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.

Why Carson tax matters call for a California-licensed firm

Carson is a South Bay LA County city of roughly 95,000 residents covering 18.7 square miles, bounded by Long Beach to the south, Torrance and Lomita to the west, Compton and Rancho Dominguez to the north, and Wilmington and the Port of LA to the southwest. The city sits at the convergence of the I-110 (Harbor Freeway), the SR-91 (Artesia Freeway), and the I-405 (San Diego Freeway), with the I-710 / I-105 corridor immediately west feeding the Port complex. The 90745, 90746, 90747, and 90810 ZIPs cover the city, with 90745 running the Wilmington-adjacent industrial west side, 90746 covering the residential core and Carson Park, 90747 anchoring the Cal State Dominguez Hills campus and the Dignity Health Sports Park area, and 90810 covering the Port-feeder logistics belt closest to the I-110 / Alameda Street corridor.

Carson's population mix is roughly one-quarter Filipino-American, one-fifth African-American, one-fifth Hispanic or Latino, and a meaningful Samoan-American and Pacific Islander community — Carson holds one of the largest Samoan-heritage populations on the U.S. mainland. The Filipino-American base ties families to Cavite, Pampanga, Pangasinan, Cebu, Iloilo, and Davao; the Samoan community ties to Samoa, American Samoa, and Tonga; the African-American community has deep roots in the post-war South Bay industrial workforce; the Hispanic community connects to Mexico, El Salvador, and Guatemala. Each diaspora carries its own FBAR, Form 8938, and Form 3520 disclosure profile.

The Carson economy splits across five sectors. Port-feeder drayage, container trucking, customs-bonded warehouses, intermodal logistics, and freight-forwarding cluster across the Watson Industrial Center along Watson Center Road and 223rd Street, the Alameda Street corridor, and the Wilmington-adjacent industrial blocks of 90810 and 90745. Two operating petroleum refineries — the Phillips 66 Wilmington Refinery on Pacific Coast Highway just south of Carson, and the Marathon Petroleum Carson Refinery on Sepulveda Boulevard inside the city — anchor a refining and refinery-services subcontracting base of operators, mechanics, instrument techs, welders, scaffolders, NDE inspectors, project managers, and lab personnel. Retail and restaurants cluster along Avalon Boulevard, Main Street, Carson Street, Sepulveda Boulevard, and at the Carson Plaza shopping center near the I-405 / Avalon interchange. Cal State Dominguez Hills at 1000 E. Victoria Street and the Dignity Health Sports Park at 18400 Avalon Boulevard anchor education and live-entertainment / professional-soccer activity. A heavy commuter residential base serves Long Beach (city, port, hospitals), Torrance (aerospace, Toyota North America legacy, Honda North America legacy), El Segundo (aerospace, SpaceX corridor), and downtown LA office employers.

Victory Tax Lawyers, LLP is a California-licensed tax-law firm. Both managing attorneys — Parham Khorsandi, Cal Bar #266658, and Amir Boroumand, Cal Bar #269570 — are members of the State Bar of California in active standing and admitted to practice before the United States Tax Court. We represent Carson clients directly before the California Franchise Tax Board, CDTFA, EDD, and the California Office of Tax Appeals — no Power-of-Attorney workaround through out-of-state counsel, no referral chain.

On the federal side, U.S. Tax Court bar admission has nationwide reach. A Carson petitioner typically designates Los Angeles as the place of trial under Tax Court Rule 140, with sessions held at the Edward R. Roybal Federal Building at 255 E. Temple Street — about 15 miles north of Carson on the I-110 / I-105. The IRS Long Beach Taxpayer Assistance Center at 501 W. Ocean Boulevard, Suite 2100 (8 miles south on I-110 / I-405), the FTB Los Angeles Field Office at 300 S. Spring Street, and the CDTFA Cerritos District Office at 12750 Center Court Drive South, Suite 400 are the day-to-day appearance venues for local administrative work. Carson's federal docket runs through the U.S. District Court for the Central District of California, Western Division, at the Roybal building. The U.S. Court of Appeals for the Ninth Circuit hears appellate work from the 95 Seventh Street San Francisco courthouse and the Pasadena courthouse at 125 S. Grand Avenue. We appear at all of these venues regularly.

The pages that follow set out the practice areas, the venue map, settlement ranges from prior cases, the seven-step engagement process, and 17 FAQs answering what Carson taxpayers actually ask.

Your tax rights as a Carson taxpayer

Federal taxpayer rights sit in the Internal Revenue Code and IRS Publication 1. California layers its own protections through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel rights inside CDTFA and EDD. Carson property owners add Prop 13 base-year and Prop 19 parent-child protections at the LA County Assessor.

Right to representation (federal)

Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview when you state you wish to consult an authorized representative. Form 2848 puts a tax attorney between you and the IRS for the rest of the matter — including the field RO who shows up at a Watson Industrial Center customs warehouse, a Phillips 66 refinery turnaround office, a CSUDH faculty residence, or an Avalon Boulevard restaurant.

Right to representation (California)

FTB Form 3520-PIT or 3520-BE appoints counsel before the Franchise Tax Board. CDTFA Form 392 covers sales-and-fuel-tax matters; EDD DE 48 covers payroll. Once on file, every notice routes to your attorney rather than your Carson address in Scottsdale Estates, Carson Park, the 90745 / 90746 / 90747 / 90810 residential blocks, or your Watson Industrial Center operation.

Right to Collection Due Process

A Notice of Federal Tax Lien (IRC §6320) or Final Notice of Intent to Levy (IRC §6330) opens a 30-day window to request a CDP hearing on Form 12153. A timely CDP request pauses federal collection and preserves Tax Court review — important on Port-feeder drayage operating-account levies, refinery-contractor accounts-receivable levies, and W-2 wage levies hitting Phillips 66, Marathon, and CSUDH paychecks.

Right to U.S. Tax Court review

A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Carson petitioners commonly designate Los Angeles as the place of trial, with sessions held at the Edward R. Roybal Federal Building at 255 E. Temple Street. San Diego is an alternative where docket timing or witness logistics call for it.

Right to an FTB protest and OTA appeal

A Notice of Proposed Assessment from the FTB carries a 60-day protest window under Cal. Rev. & Tax. Code §19041. The Notice of Action that follows opens a 30-day appeal to the California Office of Tax Appeals under §19045. The OTA is an independent tribunal that replaced the Board of Equalization on tax appeals in 2018; the Los Angeles hearing room at 355 South Grand Avenue is the closest forum to Carson.

Right to a federal OIC

Under IRC §7122, the IRS may accept less than the full liability where doubt as to collectibility, doubt as to liability, or effective tax administration justifies settlement. Filed on Form 656 with Form 433-A(OIC) or 433-B(OIC). The Reasonable Collection Potential math treats Carson refinery 1099 contractor income, single-family equity in Scottsdale Estates and Carson Park, drayage owner-operator tractor equity, and Filipino and Samoan family land interests differently than coastal LA County patterns.

Right to a California OIC

FTB compromise authority sits at Cal. Rev. & Tax. Code §19443. CDTFA runs a parallel offer program under §6832. EDD compromise sits at Cal. Unemp. Ins. Code §1735 and adjoining sections.

Right to a Collection Statute (federal 10 vs. California 20)

IRC §6502 gives the IRS 10 years from assessment to collect. The California parallel under Cal. Rev. & Tax. Code §19255 runs 20 years — double the federal tail. Pull both transcripts before negotiating any Carson resolution.

How Victory Tax Lawyers helps Carson taxpayers

Federal & California Offer in Compromise

We file federal Form 656 with Form 433-A(OIC) under IRC §7122, and FTB Form 4905 PIT or BE with the parallel California financial under Cal. Rev. & Tax. Code §19443. The two reviews run on different Reasonable Collection Potential math. Carson refinery-contractor receivables, Watson Industrial Center customs-warehouse business assets, drayage owner-operator tractor and trailer equity, single-family equity in Scottsdale Estates and Carson Park, W-2 commuter income from Long Beach and Torrance employers, and Schedule C 1099 turnaround income all need correct valuation before either filing.

Installment Agreements (IRS & FTB)

Streamlined IRS IAs under $50,000, Non-Streamlined IAs above with Form 433-F disclosure, and Partial Pay IAs under IRC §6159 running through the CSED. FTB parallel plans under Form 3567; CDTFA and EDD have their own structures. Carson refinery 1099 contractors with cyclical turnaround revenue, drayage owner-operators with seasonal freight volume, CSUDH adjuncts on per-course contracts, and Dignity Health Sports Park 1099 talent all need a structure that survives South Bay income volatility.

Lien release and withdrawal

A federal NFTL under IRC §6321 and FTB State Tax Liens under Cal. Gov. Code §7170 attach to Carson real property and record with the LA County Registrar-Recorder/County Clerk at 12400 Imperial Highway in Norwalk — the same office that handles every LA County deed, marriage certificate, and birth certificate filing. We pursue release after payment, certificate of discharge for sale or refinance, subordination on commercial refis and residential refis, and lien withdrawal under Fresh Start for IAs under $25,000.

Levy release (IRS, FTB, EDD)

Federal wage and bank levies under IRC §6331 stop with CNC, an accepted IA, OIC processing, or a timely CDP. FTB Earnings Withholding Orders under Cal. Rev. & Tax. Code §18670 and bank levies under §18670.5 release under analogous resolutions. Federal bank levies hold 21 days; FTB holds 10 business days — the shorter California window makes timing decisive on Watson Industrial Center operating accounts, refinery-contractor receivables held by AP, and W-2 wage levies hitting Phillips 66 and Marathon paychecks.

Audit and exam defense

IRS correspondence, office, and field audits handled at the Long Beach TAC and the LA federal building. FTB residency audits under Cal. Rev. & Tax. Code §17014 on Carson departures to Phoenix, Las Vegas, Henderson, Austin, and Dallas. CDTFA sales-tax audits on Avalon Boulevard, Main Street, Carson Plaza, and Carson Street retail and restaurants handled out of the CDTFA Cerritos District Office at 12750 Center Court Drive South. EDD AB 5 audits on Port-feeder drayage, last-mile delivery, restaurant labor, refinery-services subcontractors, and construction crews along the industrial corridor.

Penalty abatement

Federal First-Time Penalty Abatement and reasonable-cause requests under IRC §6651. FTB waivers under Cal. Rev. & Tax. Code §19131 and §19132. Reasonable-cause for Carson filers affected by COVID-era small-business closures, refinery-area air-quality and shelter-in-place events, the 2020-2021 South Bay wildfire smoke events, serious illness, family bereavement, and federally declared disasters under IRC §7508A.

Twelve tax issues we handle for Carson clients

Federal and California state practice areas framed for matters that walk through the door from the Port-feeder drayage and customs-warehouse base, the Phillips 66 Wilmington and Marathon Carson refinery workforce, the CSU Dominguez Hills faculty and staff, the Dignity Health Sports Park 1099 talent, the Filipino-American and Samoan-American family corridors, and the Avalon Boulevard / Main Street / Carson Street retail spine.

Port of LA / Long Beach drayage AB 5 & §7202

Carson-based owner-operators running container drayage from Pier 400, Pier 300, TraPac, Everport, and the Long Beach Container Terminal into Carson container yards fail ABC-test prong B under Cal. Lab. Code §2775. EDD assesses back UI, ETT, SDI, and PIT for three years plus penalties under UIC §1126; the federal companion at IRC §7202 reaches willful failure to collect or pay over — a five-year felony per quarter. Form 2290 federal heavy-vehicle-use tax compounds the exposure on tractors over 55,000 pounds.

Phillips 66 Wilmington / Marathon Carson refinery §401(a) lump-sum

USW Local 675-represented operators, mechanics, and instrument techs at Phillips 66 Wilmington and Marathon Carson take early-retirement lump sums under qualified §401(a) plans. Ordinary-income treatment under IRC §72, mandatory 20 percent federal withholding under §3405(c), the §72(t)(2)(A)(v) age-55 separation-from-service exception, Net Unrealized Appreciation under §402(e)(4), and direct-rollover under §402(c) are the central planning levers. Six-figure April balances are typical when withholding undershoots the combined federal-California top brackets.

Refinery 1099 turnaround contractor Schedule C

Scaffolders, insulators, NDE inspectors, instrument techs, welders, rigging crews, and project managers serving Phillips 66 Wilmington and Marathon Carson turnarounds file Schedule C with SE tax under IRC §1401. The S-corp election under §1362 splits compensation from distribution subject to Watson v. Commissioner reasonable-compensation scrutiny. Solo 401(k) and SEP-IRA contributions under §401 and §408(k) layer on. §199A QBI applies subject to W-2 wage and UBIA tests.

FBAR & Form 8938 — Filipino-American community

Carson has one of the largest Filipino-American populations in the U.S. Accounts at BPI, BDO Unibank, Metrobank, Landbank, Security Bank, RCBC, UnionBank, China Bank, PSBank, and EastWest cross the FBAR threshold under 31 USC §5314 at $10,000 aggregate; Form 8938 under IRC §6038D layers on at higher thresholds. Family land in Cavite, Pampanga, Pangasinan, Cebu, Iloilo, Davao, Bulacan, and Batangas, OFW remittance accounts, and signature authority over a parent's account all count. Form 3520 attaches separately for foreign trusts and foreign gifts above $100,000 from a non-resident alien. Streamlined Filing Compliance Procedures clear non-willful violations.

FBAR & Form 8938 — Samoan-American community

Carson holds one of the largest Samoan-heritage populations on the U.S. mainland. ANZ Samoa, BSP Samoa, National Bank of Samoa, Bank of Hawaii American Samoa, Westpac Pacific, and SamoaTel mobile-money accounts cross FBAR thresholds. The American Samoa §931 bona-fide-resident exclusion does not apply to mainland Carson residents. Customary matai-held land producing cash income, inherited family interests, and remittance accounts round out the typical exposure. Streamlined Filing Compliance Procedures clear non-willful violations.

CSU Dominguez Hills faculty CalSTRS §403(b) & §117(c) postdoc

CSUDH at 1000 E. Victoria Street anchors a faculty CalSTRS §403(b) defined-benefit pension base. IRC §117(c) postdoc and visiting-scholar stipends, NIH F32 / T32 awards, NSF and private-foundation fellowships, and 1099 versus W-2 misclassification on per-course adjuncts under Cal. Lab. Code §2775 all run through the page. CalSTRS distributions are taxed federally under §72 and by California under R&TC §17041 — California does not exempt CalSTRS.

Dignity Health Sports Park 1099 talent & §3121(q) tip

Dignity Health Sports Park at 18400 Avalon Boulevard hosts LA Galaxy training, LAFC training, U.S. Soccer national team training, the velodrome, tennis, and concert events. 1099 talent files Schedule C with SE tax under §1401. Food-and-beverage workers receiving tip income above $20 per month file Form 4137; §3121(q) attaches employer FICA to unreported tips on assessment. §181 election covers qualifying live-entertainment production costs subject to the §181(d) cap. California Film & Television Tax Credit Program 4.0 layers a 20-25 percent transferable credit.

Watson Industrial Center customs-bonded warehouse & CBP

Bonded warehouses, container freight stations, FTZ operators, and customs brokers in the Watson Industrial Center along Watson Center Road and 223rd Street manage 19 CFR Part 19 bonded-warehouse compliance, CBP entry filings, and the income-tax treatment of customs bonds and demurrage charges. Schedule C cost-of-goods-sold under §471 and inventory capitalization under §263A (UNICAP) drive the federal income side; CDTFA sales-tax and use-tax under R&TC §6051 et seq. apply on domestic distribution.

Trust Fund Recovery Penalty §6672

Under IRC §6672, the IRS reaches owners of Carson drayage LLCs, refinery-service S-corps, customs-bonded warehouse operations, restaurant ownership groups, and construction subcontractors personally for unpaid payroll trust funds after Form 4180 interviews. EDD asserts the parallel state piece under Cal. Unemp. Ins. Code §1735. The criminal companion at IRC §7202 attaches to willful failures.

Industrial-corridor §1031 commercial exchanges

Commercial sellers exchanging out of Watson Center Road, Alameda Street, Wilmington Avenue, Sepulveda Boulevard, or Avalon Boulevard parcels into replacement industrial, warehouse, or multi-family property apply IRC §1031 with the 45-day identification and 180-day closing rules. California's R&TC §18032 (FTB Form 3840) clawback requires annual reporting on out-of-state replacement property until taxable disposition. Cost-segregation studies and §168(k) bonus depreciation (phasing 60 / 40 / 20 percent for 2024-2026) stack.

FTB residency audits (Phoenix, Vegas, Texas)

Post-2020 outflow from South Bay LA to Phoenix, Scottsdale, Henderson, Las Vegas, Austin, Houston, Dallas, and Boise pulled refinery retirees, CSUDH faculty taking pension lump sums, and Port-area logistics families across state lines while many kept Carson single-family real estate as a rental. The nine-factor domicile test at R&TC §17014 puts those facts under FTB scrutiny. Appeal of Bragg (2003) and Appeal of Bindley (2018) frame the analysis.

Unreported cash income §7201

IRC §7201 tax evasion is a five-year-maximum felony with up to $100,000 in fines (or $500,000 for a corporation). IRS Criminal Investigation works the bank-deposits and net-worth methods against restaurant operators on Avalon and Main, used-car dealers, drayage subcontractors, and refinery-services LLC principals who underreport. Voluntary disclosure under the IRS Voluntary Disclosure Practice (Form 14457) avoids prosecution where timely, complete, and accurate; the §6663 civil fraud penalty (75 percent of the underpayment) still attaches.

Nine common causes of tax debt in Carson

1. Refinery union lump-sum withholding gap

Phillips 66 Wilmington and Marathon Carson union retirees taking §401(a) lump sums have only 20 percent federal withheld under §3405(c). The combined federal-California top brackets reach roughly 37 percent federal plus 13.3 percent California; the gap drives six-figure April balances. The fix runs through Streamlined or Non-Streamlined IRC §6159 IAs paired with FTB Form 3567 state plans.

2. Refinery 1099 quarterly-estimate shortfall

1099 turnaround contractors at Phillips 66 Wilmington and Marathon Carson underestimate Form 1040-ES quarterlies. SE tax under §1401 plus federal income tax plus California income tax stack on net Schedule C; a single underestimated turnaround cycle compounds quickly with §6654 estimated-tax penalty.

3. Port drayage AB 5 misclassification

Owner-operator drivers running Port of LA / Long Beach drayage out of Carson container yards routinely fail ABC-test prong B under Cal. Lab. Code §2775. EDD back-assessment under UIC §1126 plus IRC §7202 federal criminal exposure on the same payroll-withholding period compound when the hiring entity is the motor carrier rather than a true broker.

4. Small-business sales-tax underreporting

Carson restaurants on Avalon Boulevard and Carson Street, retailers in Carson Plaza, and auto dealers along Main Street draw CDTFA test-period audits out of the Cerritos District Office. Mark-up methodology under R&TC §6481 reconstructs sales from supplier invoices and observed counts; the resulting Notice of Determination must be protested within 30 days under R&TC §6561.

5. FBAR & Form 8938 omission (Philippines, Samoa, Mexico)

Filipino-American families with BPI, BDO, or Metrobank accounts, Samoan-American families with ANZ Samoa or BSP Samoa accounts, and Hispanic families with BBVA Mexico or Banorte accounts miss FBAR and Form 8938 thresholds. Penalties under 31 USC §5321 reach 50 percent of the highest balance per year for willful violations. Streamlined Filing Compliance Procedures clear most non-willful exposure.

6. CSUDH adjunct W-2 vs. 1099 confusion

Per-course adjunct faculty at Cal State Dominguez Hills receive W-2s under the CSU collective bargaining agreement, but secondary teaching, guest-lecturer, and consulting income flows on 1099-NEC. Mixed years drive Form 1040 reconciliation errors that surface as CP2000 underreporter notices 18 months later.

7. FTB residency audit after post-2020 exit

Refinery retirees, CSUDH faculty taking pension lump sums, and Port-area logistics families relocating from Carson to Phoenix, Scottsdale, Henderson, Las Vegas, Austin, Houston, Dallas, or Boise often retain a Scottsdale Estates, Carson Park, or 90745-area residence — factors the FTB weighs to assert continuing California domicile under §17014.

8. ERC clawback exposure

Employee Retention Credit claims filed by promoter mills for Carson restaurants, medical practices, retail boutiques, refinery-services LLCs, and small construction operations are being clawed back through CP207 and CP207L letters and follow-on audits. Self-corrections through the IRS ERC Withdrawal Program close exposure where the claim has not yet been paid.

9. Unreported cash income & §7201 exposure

Cash sidework, undeposited 1099-K omissions across the Carson small-business economy, and unreported tip income at Dignity Health Sports Park concessions generate IRS notices that escalate from civil §6663 fraud penalties to criminal §7201 evasion exposure when the unreported amount and pattern of conduct meet IRS Criminal Investigation thresholds.

Who is on the hook: eight Carson liability scenarios

Joint filers (community-property state)

California is a community-property state under Cal. Fam. Code §760. Joint federal returns create joint-and-several liability under IRC §6013(d)(3). One Carson spouse can be pursued for the entire balance — even post-divorce — subject to Innocent Spouse Relief under IRC §6015 and R&TC §18533.

Divorce and tax allocation at LA County Superior Court

The LA County Superior Court Compton and Long Beach courthouses hear Family Court matters for the South Bay region. Allocation of joint federal liability, refinery pension and RSU treatment as community property, small-business asset division, and stock-option division under Marriage of Hug all bear on the tax case. We coordinate with family-law counsel.

Responsible persons for payroll trust funds

TFRP under IRC §6672 reaches anyone with check-signing authority who willfully failed to pay over withheld taxes. IRC §7202 criminal exposure attaches to willful failure to collect or pay over. Carson drayage, refinery-services, customs-bonded warehouse, restaurant, retail, and contractor industries draw this risk. EDD's state TFRP analog is at UIC §1735.

CDTFA dual-determinations

CDTFA can issue personal dual-determinations against corporate officers, directors, and LLC members for unremitted sales tax under Cal. Rev. & Tax. Code §6829. Common with Avalon Boulevard, Carson Street, Main Street, and Carson Plaza retail, restaurant, and used-car operations where the entity has wound down or filed bankruptcy.

FTB suspended-entity exposure

A Carson LLC suspended by FTB under R&TC §23301 loses its right to contract or defend in California courts. Officers signing on behalf may incur personal exposure. Common with single-member small-business LLCs that miss the $800 minimum franchise tax during drayage off-seasons or refinery-turnaround downcycles. Revive via Form 3557 once compliance is current.

Transferee liability (Prop 19, family transfers)

IRC §6901 reaches transferees where the transfer rendered the transferor insolvent and tax debt remains. Common with Prop 19 parent-child transfers of Carson real estate since the 2021 Prop 19 effective date narrowed the parent-child exclusion to primary residences, pulling most rental, second-home, and small-commercial transfers into reassessment territory.

Successor business liability

Asset purchases continuing a seller's Carson operation can carry CDTFA successor liability under R&TC §6811-6814 and EDD successor liability under UIC §1731. Buyers protect with CDTFA clearance letters before close — especially on Avalon and Carson Street restaurant acquisitions, Main Street auto-dealer acquisitions, Watson Industrial Center warehouse acquisitions, and refinery-services LLC acquisitions.

Estate and decedent returns

California has no state estate tax, but federal estate-tax planning under §2010 (unified credit), the §6166 estate-tax installment plan, the QTIP election under §2056(b)(7), and the stepped-up basis at death under §1014 are the central planning levers for Carson estates — particularly significant where the decedent held Filipino or Samoan family land overseas and personal liability under 31 USC §3713(b) attaches to the executor for premature distributions.

What resolution can look like in Carson

Debt reduced

An accepted federal OIC settles the IRS liability for less than the full amount. A parallel FTB §19443 compromise can settle the California side. Partial Pay IAs cap recovery at what you can pay through the federal CSED or the FTB 20-year statute. Currently Not Collectible status freezes federal collection during refinery layoffs, drayage seasonal downturns, family transitions, and serious illness.

Penalties abated

Federal First-Time Penalty Abatement removes failure-to-file and failure-to-pay penalties for a clean compliance year. Reasonable-cause requests address COVID-era closures, refinery-area shelter-in-place events, federally declared disasters under IRC §7508A, and serious illness. FTB waivers under §19131 and §19132 follow parallel principles.

Liens and levies released

A federal NFTL recorded with the LA County Registrar-Recorder at 12400 Imperial Highway in Norwalk withdraws once a streamlined IA is in place under Fresh Start. FTB State Tax Liens release on payment, compromise, or release-for-cause. Wage and bank levies stop when the matter moves to CNC, IA, or OIC processing.

Outcomes vary. Past results do not guarantee future outcomes. Each tax case is unique.

Settlement ranges from the firm’s case files

The following ranges come from Victory Tax Lawyers cases over the past several years and contribute to the firm’s $100M+ aggregate tax-relief figure. Names and identifying facts are removed for confidentiality.

Matter type Original liability Resolution Approximate result
Installment Agreement $138,296 IRC §6159 streamlined IA $25/month accepted
Partial Pay IA $126,489 IRC §6159 PPIA through CSED $50/month accepted
Installment Agreement $128,206 IRC §6159 streamlined IA $25/month accepted
Partial Pay IA $116,451 IRC §6159 PPIA through CSED $50/month accepted
Installment Agreement $152,296 IRC §6159 streamlined IA $25/month accepted

Past results do not guarantee future outcomes. Each tax case is unique and turns on facts, asset position, monthly disposable income, IRS Allowable Living Expense tables, FTB equivalent standards, and the discretion of the assigned Revenue Officer, Settlement Officer, or FTB compromise reviewer. Acceptance rates for federal Offer in Compromise vary widely — the IRS reported a nationwide acceptance rate of roughly 30 to 40 percent in recent years.

Why work with a California-licensed firm on a Carson tax matter

A Carson tax matter rarely sits in one forum. A federal CP2000 underwithholding bill on a Phillips 66 or Marathon refinery W-2 triggers a parallel California assessment within four years through the federal-state information-exchange agreement. A CDTFA sales-tax audit on a Carson Plaza restaurant generates an EDD payroll-tax audit on the same set of employees, and an IRS Schedule C exam on the same business return. An FTB residency audit on a refinery retiree relocating to Phoenix pulls in LA County property records from the Assessor and Registrar-Recorder. An IRC §1031 exchange out of a Watson Center Road warehouse parcel combines federal cost-segregation acceleration with FTB Form 3840 clawback reporting. A drayage owner-operator AB 5 reclassification stacks IRC §7202 criminal exposure on top of EDD UIC §1126 back-assessment. An FBAR or Form 8938 omission on a Filipino-American family's BPI or BDO account, or a Samoan-American family's ANZ Samoa account, opens both federal Streamlined Filing and parallel FTB compliance. These matters do not stay in their lanes.

Victory Tax Lawyers is admitted in California, headquartered in Los Angeles, and built around this overlap. Parham Khorsandi (Cal Bar #266658) and Amir Boroumand (Cal Bar #269570) appear directly before the FTB, CDTFA, EDD, and OTA, and on the federal side before the IRS and the U.S. Tax Court. The same attorneys handle the whole engagement — no Form 2848 workaround, no referral chain through out-of-state counsel.

California Rule of Professional Conduct 7.1 governs lawyer advertising in the state. No superlatives without verifiable substantiation, no specific dollar guarantees, no testimonials without disclaimers. The firm operates under those rules natively. This page does not promise outcomes, does not promote dollar averages, and does not list testimonials without context.

If your case is purely federal — an IRS audit, a Tax Court petition with Los Angeles place of trial, an Offer in Compromise — we handle it under Tax Court bar admission, Circular 230, and a Form 2848 Power of Attorney. The California-licensed difference shows up when the state side appears, which it usually does in Carson.

The seven steps of a VTL tax-resolution engagement

1

Free consultation

A 30-minute call with an attorney to outline the facts, the IRS or FTB notices received, and realistic resolution options.

2

Engagement letter

A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law privilege both attach.

3

Federal & state PoA

Form 2848 filed with the IRS, FTB Form 3520, CDTFA Form 392, or EDD DE 48 filed with the relevant California agency. Notices route to counsel.

4

Transcript investigation

IRS Account Transcripts, Wage-and-Income Transcripts, and Record of Account pulled across all open years. FTB MyFTB, CDTFA, and EDD records pulled. Federal CSED and California 20-year statute dates verified.

5

Strategy memo

A written analysis recommending federal OIC, IA, CNC, audit response, CDP, or Tax Court petition with the FTB, CDTFA, or EDD parallel strategy where applicable.

6

Resolution filed

Federal Forms 656, 433-A, 9423, 12153, or Tax Court Petition. State FTB Form 4905, CDTFA offer, or EDD compromise. Negotiations with Revenue Officers, Settlement Officers, Appeals Officers, FTB analysts, CDTFA supervisors, and OTA hearings handled directly.

7

Compliance close-out

Post-resolution monitoring: quarterly estimates, return filings, and protection against IA default. The case is done when the new pattern is stable, not when the offer is accepted.

Collection statute warning — the California 20-year tail

Under IRC §6502(a), the IRS has ten years from the date of assessment to collect. After the federal Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Tolling events extend the federal CSED: a pending OIC (extends by OIC pendency plus 30 days), bankruptcy (extends by stay plus six months), Collection Due Process hearings, Innocent Spouse claims, and continuous absence from the United States for six months or more.

The California side is the opposite of forgiving. Under Cal. Rev. & Tax. Code §19255, the FTB has 20 years from the latest of assessment, due date, or final return filing to collect — double the federal CSED. CDTFA collection runs 10 years under §6711 with similar tolling. EDD operates under its own collection window in the Unemployment Insurance Code.

A federal Carson balance assessed in 2016 may approach CSED expiration in 2026, while the FTB equivalent continues to be collectible until 2036. Submitting a federal OIC restarts the federal clock. Sometimes a Partial Pay IA that runs out the federal statute is the better federal play, paired with a separate FTB compromise to address the longer state tail. The two strategies are decided together.

Carson venue: federal and state tax forums

A Carson tax matter may proceed in any of several federal or state forums depending on the type of liability. Below are the offices, courthouses, and agencies serving the city.

U.S. Tax Court — Los Angeles trial sessions

The United States Tax Court holds Southern California trial sessions at the Edward R. Roybal Federal Building and U.S. Courthouse, 255 E. Temple Street, Los Angeles CA 90012 — about 15 miles north of Carson on the I-110 / I-105. A Carson petitioner designates “Los Angeles, California” as the place of trial on the petition under Tax Court Rule 140. San Diego is an alternative where docket timing or witness logistics warrants it.

IRS Long Beach Taxpayer Assistance Center

The IRS operates a TAC at 501 W. Ocean Boulevard, Suite 2100, Long Beach CA 90802 — about 8 miles south of Carson on I-110 / I-405. Appointments through apps.irs.gov/app/office-locator or 844-545-5640. The LA federal building at 300 N. Los Angeles Street is the alternative if the Long Beach TAC calendar is full. For most resolution work, in-person visits are not required — we represent clients by Form 2848 PoA.

U.S. District Court — CDCA, Western Division

Federal refund suits and criminal-tax cases proceed in the U.S. District Court for the Central District of California, Western Division, at the Edward R. Roybal Federal Building, 255 E. Temple Street, Los Angeles CA 90012, and at the First Street Courthouse at 350 W. 1st Street. The CDCA Southern Division at the Ronald Reagan Federal Building, 411 W. 4th Street, Santa Ana CA 92701 handles some Orange-County-line routing. Ninth Circuit appeals run from 95 Seventh Street in San Francisco and the Pasadena courthouse at 125 S. Grand Avenue.

FTB Los Angeles Field Office (300 S. Spring St)

The California Franchise Tax Board Los Angeles Field Office at 300 S. Spring Street, Los Angeles CA 90013 is the home FTB office for Carson residents and businesses: residency audits under R&TC §17014, Notice of Proposed Assessment protests under §19041, FTB Settlement Bureau review under §19443, and walk-in services for individual taxpayers. Verify current public hours through ftb.ca.gov/help/contact/office-locations.html before any walk-in visit.

CDTFA Cerritos District Office (12750 Center Court Drive South)

The California Department of Tax and Fee Administration Cerritos District Office at 12750 Center Court Drive South, Suite 400, Cerritos CA 90703 is the home CDTFA office for Carson sales-tax, fuel-tax, and IFTA matters — about 13 miles east on SR-91. CDTFA's prior Norwalk field office at 12440 E. Imperial Highway, Suite 200 relocated to Cerritos in November 2017 (CDTFA notice L-513). Petitions for Redetermination under R&TC §6561, appeals conferences, and offer reviews route through Cerritos.

LA County Superior Court (Compton & Long Beach courthouses)

The Los Angeles County Superior Court Compton Courthouse at 200 W. Compton Boulevard, Compton CA 90220 and the Long Beach Courthouse at 275 Magnolia Avenue, Long Beach CA 90802 hear Family Court and Civil matters for the South Bay region. State-tax civil collection, divorce-tax allocation, and probate-tax matters proceed at these venues for Carson litigants. R&TC §19382 / §19385 refund suits are filed in LA County Superior Court — the Stanley Mosk Courthouse at 111 N. Hill Street, downtown LA, is the general civil-tax-litigation venue.

LA County Registrar-Recorder/County Clerk (12400 Imperial Highway, Norwalk)

The LA County Registrar-Recorder/County Clerk at 12400 Imperial Highway, Norwalk CA 90650 records federal Notices of Federal Tax Lien under IRC §6323, FTB State Tax Liens under Cal. Gov. Code §7171, deeds of trust, quitclaim transfers, satisfaction-of-mortgage filings, marriage and birth certificates, and the bulk of LA County official records. A Carson tax lien records here, and lien release, certificate of discharge, subordination, and withdrawal filings all route through this office.

LA County Assessor & AAB (500 W. Temple St)

The LA County Assessor at 500 W. Temple Street, Los Angeles CA 90012 administers Prop 13 base-year values, Prop 19 parent-child transfers, supplemental assessments, and the property roll. The Assessment Appeals Board hears reassessment petitions under R&TC §1603-1611 from offices at 500 W. Temple Street, Suite B-4. LA County uses the November 30 filing deadline for the regular roll; supplemental and escape assessments carry a 60-day window from the Notice of Assessment under §1605(e).

LA County Treasurer-Tax Collector (225 N. Hill St)

The LA County Treasurer-Tax Collector at 225 N. Hill Street handles property-tax billing and collection across the county. Property-tax delinquencies on Scottsdale Estates, Carson Park, and 90745 / 90746 / 90747 / 90810 parcels proceed through this office, with the five-year redemption window under R&TC §3691 before the property moves to the tax-defaulted property sale.

California Office of Tax Appeals (Los Angeles hearing room)

The California Office of Tax Appeals is headquartered in Sacramento with a Southern California hearing room at 355 South Grand Avenue in Los Angeles — the closest OTA forum for Carson taxpayers. OTA petitions follow a 30-day window from an FTB or CDTFA Notice of Action under R&TC §19045 / §19324.

California Court of Appeal, 2nd District

Appeals from LA County Superior Court go to the California Court of Appeal, Second Appellate District, with eight divisions hearing matters at 300 S. Spring Street and 200 E. Temple Street in downtown LA. The Second District serves LA County and Ventura County.

City of Carson — business license, UUT & TOT

The City of Carson administers the business-license tax under Carson Municipal Code Chapter 3 from City Hall at 701 E. Carson Street, Carson CA 90745, phone (310) 952-1700. The city imposes a Utility Users Tax on telephone, electricity, gas, water, and video service under Chapter 3, and a Transient Occupancy Tax on hotel and short-term-lodging operators. Watson Industrial Center operations, Avalon Boulevard restaurants, Main Street auto dealers, Carson Plaza retail, and Sepulveda Boulevard refinery-services LLCs need current Carson business licenses on file. Past-due city business taxes can become a lien on the underlying real property under California Government Code §38773.

Request a free consultation with a Carson tax attorney

A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, last filed federal and California returns, any FTB or CDTFA or EDD correspondence, and — if you run a Watson Industrial Center customs warehouse or drayage operation, work the Phillips 66 Wilmington or Marathon Carson refinery W-2 or 1099 turnaround line, teach at CSU Dominguez Hills, contract through Dignity Health Sports Park, or have foreign accounts in the Philippines, Samoa, or Mexico — your most recent W-2, 1099, K-1, Schedule E, or Schedule C. We will tell you which resolution options fit your facts on both sides before you sign anything.

Principal office: 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Statewide California service including Carson and all of Los Angeles County.

Frequently asked questions — Carson

Author & reviewer

Parham Khorsandi, Esq.

Written by Parham Khorsandi, Esq.

Managing Attorney · California Bar #266658 · Pepperdine Caruso School of Law, JD 2009 · Admitted to the United States Tax Court

Parham Khorsandi is a managing attorney of Victory Tax Lawyers, LLP, headquartered at 1100 S. Robertson Boulevard in Los Angeles. His practice covers federal and California tax controversy across the state, including Carson matters: Port of LA and Port of Long Beach drayage AB 5 reclassification with IRC §7202 trust-fund-tax exposure and Form 2290 federal heavy-vehicle-use-tax representation for Carson-based owner-operators; Phillips 66 Wilmington Refinery and Marathon Carson Refinery union §401(a) qualified-plan lump-sum representation with §72(t)(2)(A)(v) age-55 separation analysis, Net Unrealized Appreciation under §402(e)(4), and direct-rollover planning under §402(c); refinery-services 1099 turnaround contractor Schedule C representation with S-corp election analysis under §1362; Watson Industrial Center customs-bonded warehouse and bonded-FTZ operator income-tax representation; Cal State Dominguez Hills faculty CalSTRS §403(b) and adjunct misclassification matters; Dignity Health Sports Park 1099 talent, §3121(q) tip, and §181 entertainment-production representation; Filipino-American FBAR and Form 8938 representation for cross-border accounts at BPI, BDO, Metrobank, Landbank, Security Bank, RCBC, UnionBank, China Bank, PSBank, and EastWest; Samoan-American FBAR representation for accounts at ANZ Samoa, BSP Samoa, National Bank of Samoa, and Bank of Hawaii American Samoa; Mexican-American FBAR representation for BBVA Mexico, Banorte, and Santander Mexico accounts; Form 3520 foreign-trust and foreign-gift reporting; IRC §1031 commercial real-estate exchanges on the Watson Center Road, Alameda Street, Sepulveda Boulevard, and Avalon Boulevard industrial corridors with FTB Form 3840 clawback reporting; FTB residency audits following moves to Phoenix, Las Vegas, Henderson, Austin, Houston, and Dallas; LA County Assessment Appeals Board petitions for Prop 13 and Prop 19 reassessment disputes; payroll-tax and Trust Fund Recovery Penalty defense for Avalon Boulevard, Carson Street, Main Street, and Carson Plaza small-business operators; City of Carson business-license and Utility Users Tax matters under Carson Municipal Code Chapter 3; and U.S. Tax Court petitions designated to the Los Angeles trial city.

Last Reviewed:

Amir Boroumand, Esq.

Reviewed by Amir Boroumand, Esq.

Managing Attorney · California Bar #269570 · Admitted to the United States Tax Court

Reviewed for accuracy of California statutory citations (R&TC, UIC, Government Code, Carson Municipal Code), federal Internal Revenue Code citations (§401(a), §72(t), §402(e), §7202, §6672, §6502, §5314, §6038D, §181, §3121(q), §117(c)), named California entities (FTB Los Angeles Field Office, CDTFA Cerritos District Office, OTA Los Angeles, LA County AAB, LA County Registrar-Recorder at 12400 Imperial Highway, LA County Treasurer-Tax Collector at 225 N. Hill Street, City of Carson at 701 E. Carson Street), and consistency with California Rule of Professional Conduct 7.1 on lawyer advertising. Dual-attorney review is the firm’s standard for geographic-practice content.

Attorney Advertising. Victory Tax Lawyers, LLP is a California-licensed law firm with its principal office at 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Information on this page is general in nature, may not reflect the most recent legal developments, and does not create an attorney-client relationship. This page is not legal advice. Federal and California tax outcomes depend on individual facts and the discretion of the Internal Revenue Service, the Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, or the relevant tribunal. Past results do not guarantee future outcomes; each tax matter is unique.

IRS Circular 230 Disclosure. To ensure compliance with requirements imposed by the IRS, any U.S. federal tax advice contained on this page is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.

California-specific note. VTL attorneys are members of the State Bar of California in active standing. California state-tax matters (FTB, CDTFA, EDD, OTA) and federal IRS / U.S. Tax Court matters are handled directly by the firm. CDTFA sales-tax and fuel-tax matters serving Carson run out of the Cerritos District Office at 12750 Center Court Drive South. FBAR and Form 8938 reporting for Carson's Filipino-American, Samoan-American, and Mexican-American communities, IRC §1031 exchanges on the Watson Center Road and Sepulveda Boulevard industrial corridors, Phillips 66 Wilmington and Marathon Carson refinery union §401(a) lump-sum analysis, FTB residency audits, and LA County Assessor reassessment petitions each require accurate underlying documentation. Consult a licensed attorney about your specific situation before acting on any content on this page. California Rule of Professional Conduct 7.1 requires that lawyer communications not be false or misleading; this page strives to comply and does not promise specific outcomes.

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Live reviews from Victory Tax Lawyers' Google Business Profile (1100 S Robertson Blvd, Los Angeles). Updated Jun 17, 2026.