Tax Attorney in Fresno County

Fresno. The U.S. Tax Court holds Central Valley trial sessions at the Robert E. Coyle Federal Building, 2500 Tulare Street, Room 4401, Fresno. Fresno County petitioners designate Fresno as the preferred place of trial on the petition under Tax Court Rule 140. From most of the county — the city of Fresno, Clovis, Sanger, Reedley, Selma — that is a short drive. From Coalinga, Mendota, or Huron on the west side, the trip is under an hour. Most cases settle before trial through Office of Chief Counsel negotiations, but the local trial venue means hearings, calendar calls, and witness appearances stay close to home.

Two different IRS facilities are both in Fresno, and people frequently confuse them. The IRS Taxpayer Assistance Center (TAC) is at 2525 Capitol Street, Fresno, CA 93721 — that is the walk-in office for individual taxpayer support, by appointment through 844-545-5640. The IRS Fresno Service Center is at 5045 E Butler Avenue and is a return-processing and correspondence facility, not a public service location. Mail goes there, but people do not. For active controversy work — CP2000s, audit responses, levy releases — counsel-driven communication with the assigned Revenue Officer or Settlement Officer is the right channel, not the TAC.

Yes — IRC §1301 allows an individual engaged in a farming or fishing business to elect income averaging on Schedule J. You take a portion of your current-year elected farm income, divide it equally across the three prior tax years, and tax it at the rates that applied in those years. For a Fresno County grower coming off a high-price grape, almond, or pistachio year following several lower-revenue years, the bracket-smoothing effect can drop the federal tax bill substantially. The election is on Schedule J of Form 1040, made by the due date of the return. We routinely re-run prior-year returns to find missed Schedule J opportunities and amend where the window remains open under IRC §6511.

Under IRC §451(f), a cash-method farmer who receives crop-insurance or federal-disaster proceeds because of crop destruction or damage may elect to defer reporting the income to the following tax year, if the farmer's usual practice is to sell more than 50 percent of the crop in the year after harvest. The election is made by attaching a statement to the return that identifies the cause of destruction, the date of destruction, the amount received, and the fact of the deferral election. We see Fresno County clients miss this election routinely — particularly on payouts from RMA federal crop insurance, NAP coverage, and ad-hoc disaster aid like ERP. If the original return was filed without the election, amending under IRC §6511 may still be possible depending on timing.

Probably yes, on both federal and state sides. Federal IRC §6672 assesses a Trust Fund Recovery Penalty against any "responsible person" who "willfully" failed to pay over withheld taxes — the FICA and federal income-tax-withholding portion of Form 941, not the employer's share. The IRS conducts a Form 4180 interview to identify responsible persons. Anyone with check-signing authority, payroll-decision authority, or knowledge of unpaid taxes can be assessed. On the California side, Cal. Unemp. Ins. Code §1735 assesses personal liability for EDD payroll-tax withholding (SDI, PIT withholding) against the same class of responsible persons. CDTFA sales-tax personal liability under Cal. Rev. & Tax. Code §6829 operates under similar principles. We pull the trust-fund schedule first, then defend the responsible-person analysis at the 4180 interview.

Often yes, for some period of time. California uses the domicile test at Cal. Rev. & Tax. Code §17014, fleshed out in FTB Publication 1031, which weighs nine factors: time in state, location of family, location of primary residence, where you hold a driver's license, where you register vehicles, where you vote, where you bank, where you maintain professional licenses, and where you have business or social ties. The FTB regularly pursues Central Valley residents who relocated to Texas, Idaho, Nevada, or Tennessee — especially where farmland, packing-shed interests, or family ties remain in Fresno County. A clean break documented at the time of the move is the strongest defense. We see FTB residency audits run two to three years after the move and defend Fresno County clients who thought the cross-state move closed the California chapter.

Substantial. A direct sale of orchard ground without a IRC §1031 like-kind exchange recognizes the entire built-in gain in the year of sale. Federal capital gains plus the 3.8 percent Net Investment Income Tax under IRC §1411 (if applicable), and California treats the gain as ordinary income up to 13.3 percent — plus the §17043 Mental Health Services Act 1 percent surtax above $1 million. On a long-held Fresno County orchard with deep basis differential, the combined federal-state bill can run 30 to 38 percent of the gain. Section 1031 deferral requires identification within 45 days and closing within 180 days, using a qualified intermediary. We unwind failed exchanges, recover basis through Schedule F depreciation, and where the sale has closed and the deferral window is gone, we plan the resulting tax balance through IRC §6159 installment agreements or a Partial Pay IA.

It depends on the volume and the nature of the side work. Pure Schedule C reporting works for modest consulting income. As 1099 revenue scales, an S-corporation loan-out can pull some payroll-tax savings out of the distribution portion — but specified-service-trade-or-business limits under IRC §199A may phase out the Qualified Business Income deduction for many professional services at higher income, and reasonable-compensation analysis becomes a real audit risk. Quarterly estimated payments under IRC §6654 are required on the side income, and the IRS Fresno Service Center catches the gap quickly when wages and 1099 income are both reported by California State University, Fresno and outside payers. California adds the 13.3 percent ordinary-income layer, plus §17043 surtax above $1 million. The right structure is fact-specific; we map it before recommending it.

A federal Notice of Federal Tax Lien under IRC §6321 is recorded against real property at the Fresno County Clerk-Recorder's office in downtown Fresno. NFTLs on personal property (entities) are filed centrally with the California Secretary of State. The FTB State Tax Lien under Cal. Gov. Code §7170 follows a parallel path. Both clouds show up in title work, both can be released after payment, accepted offer, or release-for-cause, and both can be withdrawn under specific programs (federal Fresh Start for IAs under $25,000; FTB has its own release procedures). For refinancing through Farm Credit West or a regional ag-lender on operating-loan renewals, a Certificate of Discharge of Property from Federal Tax Lien (Form 14135) can clear a specific parcel without paying the whole debt.

Yes — three of them. FTB compromise authority sits at Cal. Rev. & Tax. Code §19443 (FTB Form 4905 PIT for individuals, 4905 BE for entities). CDTFA operates a parallel offer program for sales-and-use tax. EDD compromise authority sits at Cal. Unemp. Ins. Code §1192 for payroll-tax liabilities. Each program has its own form, financial disclosure standard, and review path. Submitting an FTB OIC does not affect a federal IRS OIC — the two are evaluated by separate teams under different Reasonable Collection Potential standards. California is generally tougher on agricultural equipment, irrigation infrastructure, and primary-residence equity than the IRS is, so the parallel offers do not necessarily land at the same number.

Your federal CSED is calculated from the date of assessment, which appears on your IRS Account Transcript as Transaction Code 150 (return filed) or Transaction Code 290 (additional assessment). Add ten years under IRC §6502, then add days for tolling events (pending OICs, CDP hearings, bankruptcy stays, continuous absence from the US for six months or more). The IRS publishes the CSED on its internal CC ACTRA transcript; we pull this as part of every Fresno County engagement. The California 20-year statute under Cal. Rev. & Tax. Code §19255 runs independently — an FTB liability does not expire when the federal CSED runs. For someone who moved out of California and is waiting out the FTB clock, that twenty-year tail is the binding constraint.

Yes. IRC §7345 authorizes the IRS to certify "seriously delinquent" federal tax debt — currently $62,000 for 2026, indexed for inflation — to the State Department, which may deny passport renewal or revoke an active passport. Certification reverses when the debt is paid, an Installment Agreement is in place, an OIC is accepted, an active CDP hearing is pending, or Innocent Spouse Relief is in process. This catches Central Valley farmers and exporters with overseas buyer relationships, dual-national families with frequent travel to Mexico, Southeast Asia, India, or the Middle East, and Fresno County exporters working with international customers. We decertify before travel by establishing one of the reversal categories.

No. The firm is headquartered at 1100 S. Robertson Boulevard in Los Angeles, but we represent clients throughout Fresno County — from Fresno and Clovis to Coalinga, Huron, Mendota, Reedley, Orange Cove, and the unincorporated foothills and west side. Most engagements run by phone, secure portal, and email, with Form 2848 federal Power of Attorney and FTB Form 3520 PIT signed at the start so every notice routes to counsel. In-person meetings happen by appointment at the LA office for clients who prefer face-to-face. Spanish-language client service is available; Hmong-language matters work through certified translators on document review.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues — Schedule F farm-income examinations with USDA payment reconciliation and crop-insurance timing issues run on the higher end. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with complexity. California-state matters (FTB, CDTFA, EDD, OTA) are priced separately. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparisons claiming we are cheaper or faster than competitors without verifiable substantiation, so we do not market on price.