Tax Attorney in Glenn County

Yes — in Sacramento. The U.S. Tax Court designates Sacramento as a place of trial under Tax Court Rule 140. Sessions are held at the Robert T. Matsui U.S. Courthouse at 501 I Street, Sacramento 95814, roughly an hour and a half from Willows south on Interstate 5. Glenn County petitioners typically designate Sacramento on Tax Court petitions, which avoids the longer drive to San Francisco or Los Angeles for trial. The Court calendars Sacramento sessions several times per year.

Both the Treasurer-Tax Collector and the Assessor operate from 516 W. Sycamore Street in Willows — the Courthouse Annex right next door to the historic Willows Courthouse at 526 W. Sycamore Street, where the Superior Court sits. The Treasurer-Tax Collector handles property-tax billing, collection, payment plans for defaulted property, and the annual tax-defaulted property auction. The Assessor sets the assessed value of each parcel. Disputes over assessed value go to the Assessor, then to the Glenn County Assessment Appeals Board. Disputes over the amount owed or the bill itself go to the Treasurer-Tax Collector. Prop 13 base-year-value transfers, Prop 19 parent-to-child exclusions on family rice and orchard ground, Prop 8 decline-in-value applications, Williamson Act ag-preserve contracts under Cal. Gov. Code §51200, and supplemental assessments on ownership transfers all route through the Assessor.

IRC §1301 lets a qualifying farmer or fisherman elect to compute current-year tax as if a portion of current-year elected farm income had been received ratably over the prior three base years. The election is made on Schedule J and applies only to the federal calculation. For a Glenn County rice operation coming off two lean years with a strong harvest in the current year, the math frequently saves five to eight points on the effective federal rate — the high year drops out of the top brackets and the base years fill out their lower brackets at the prior-year rates. The catch is that California conforms only partially to §1301 through Cal. Rev. & Tax. Code §17081, and the FTB analysis runs separately on a Schedule CA adjustment. Also worth noting: prior-year self-employment tax is not recomputed under the election, so the Schedule SE position holds. Run the election when the cycle calls for it; run it through the math in both years before you file.

Yes, in most cases. Under IRC §451(f), a cash-method farmer who receives federal crop-insurance or federal disaster proceeds for a destroyed crop may elect to include the proceeds in income for the tax year following the year of the loss, provided the grower can show that under normal business practice the income would have been received in the following year. The election is made on the timely-filed return for the year the proceeds were received. For Glenn County rice and prune growers, the normal business practice is to deliver to the dryer or packer and receive payment over a multi-week to multi-month cycle that often straddles the calendar year — the §451(f) deferral generally fits. The election does not apply to commodity-credit loan proceeds (those have their own deferral mechanic under §77) and does not apply to revenue-protection or area-yield products that pay regardless of loss in the same accounting cycle. Document the loss event, the carrier's settlement date, and the normal payment timing for your crop and your delivery point.

Generally capitalize under IRC §263A(d). The Uniform Capitalization rules require farmers to capitalize the pre-productive period costs of plants and trees with a pre-productive period exceeding two years — which covers almonds (three to four years to first commercial crop), walnuts (five to seven years), prunes (four to five years), and most other Glenn County permanent crops. Pre-productive period costs include site preparation, trees and rootstock, irrigation infrastructure, dust, water, labor, and an allocable share of management overhead. The amounts capitalize into the basis of the planted crop and depreciate once the orchard reaches commercial production, typically over a 10-year MACRS life for almonds (and a longer life for walnuts and prunes). The grower can elect out of §263A under §263A(d)(3), which permits current deduction but requires the use of the Alternative Depreciation System (a longer recovery period). The election is irrevocable for the planting. The decision turns on whether current cash-flow tax relief is more valuable than the longer-term depreciation. Once filed wrong, a 481(a) adjustment under examination pulls the prematurely expensed pre-productive costs back into income in one tax year.

Under IRC §1014, property acquired from a decedent takes a basis equal to the fair market value at the date of death (or the alternate valuation date six months later if elected on Form 706). That is the "step-up" — it wipes out any unrealized appreciation that accrued during your grandfather's ownership. For a Stony Creek grazing parcel that was carried at a low original cost basis from a 1950s or 1960s acquisition, the step-up to current FMV can be transformative. Get a written appraisal contemporaneously with the date of death — not five years later when you decide to sell. The appraiser should be a certified-general appraiser experienced in rural-ag and timberland valuation; the appraisal needs to be Uniform Standards of Professional Appraisal Practice (USPAP) compliant. The same step-up applies separately to inherited cattle herds (treat breeding stock as Section 1231 assets with a stepped-up basis equal to FMV per head at date of death), inherited equipment, and any inherited interest in a family ranching LLC or LP. For a community-property household, the surviving spouse takes a full double step-up on the entire parcel under IRC §1014(b)(6), not just on the decedent's half — a meaningful California-specific benefit.

Yes — three of them. FTB compromise authority sits at Cal. Rev. & Tax. Code §19443 (filed on FTB Form 4905 PIT for individuals or 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. The FTB §19443 compromise unit sits in headquarters at 9646 Butterfield Way in Rancho Cordova, roughly an hour and a half south of Willows on Interstate 5. Submitting an FTB OIC does not affect a federal IRS OIC; the two are evaluated by separate teams under different RCP standards, and California is generally tougher on primary-residence equity than the IRS — which matters when the Glenn County primary residence sits on the same parcel as the family farming operation and the equity calculation runs into question.

Two periods matter. For FTB assessment, Cal. Rev. & Tax. Code §19057 generally gives the FTB four years from a filed return to assess, with no statute on unfiled returns. For FTB collection, §19255 gives the FTB 20 years from the latest of assessment, due date, or final return filing — double the federal 10-year period under IRC §6502. CDTFA assessment runs three years under §6487 (eight for unfiled or fraud), with collection generally 10 years under §6711. EDD has its own windows under the Unemployment Insurance Code. A Glenn County filer who watches the federal CSED expire in 2026 may still face FTB collection until 2036 on the same year — and the FTB's reach into California-source farm income survives a move to Nevada, Idaho, or anywhere else.

Yes. The IRS examines federal income tax under the Internal Revenue Code; the FTB examines California state income tax under the Revenue and Taxation Code. The two agencies operate independent audit programs but share information through formal information-exchange agreements. An IRS adjustment to federal taxable income is reported to the FTB under the federal-state agreement, and a Revenue Agent Report can trigger a parallel California assessment within four years. CDTFA sales-tax audits and EDD payroll audits can run alongside both. A single Glenn County small business — say, a Willows ag-supply retailer, an Orland almond huller, or a Hamilton City equipment dealer — can have a 2022 tax year open in four different forums at once.

Probably yes, on both 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. For a Willows or Orland ag-supply retailer, an almond or walnut huller, a prune dehydrator, a small construction firm working the Sacramento Valley, or a Hamilton City restaurant that closes with unpaid 941s, the owner usually faces all three exposures simultaneously.

It depends on whether you materially participate in the farming operation. If you simply rent the ground for a fixed cash rent and the tenant does all the farming, you report on Form 4835 as a non-material-participation farm-rental landlord — that income is not subject to self-employment tax. If you take a share of the crop and materially participate (regular involvement in farming decisions, advancing inputs, sharing risk on yield and price), you report on Schedule F with self-employment tax exposure. The IRS uses the seven-test material-participation standard under the Section 469 regulations as a starting point. Many Glenn County retiree-landlords are reporting Schedule F when Form 4835 is the more accurate position — or vice versa. The classification matters at Social Security earnings-test transitions, at retirement, on inherited-property successions, and in any audit posture where the FICA exposure is part of the assessment. Confirm the lease structure, the operating decisions, and the cash-flow allocation against the reporting form before the return is filed.

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 then deny passport renewal or revoke an active passport. Certification reverses when the debt is paid, an IA is in place, an OIC is accepted, an active CDP hearing is pending, or Innocent Spouse Relief is in process. Glenn County farm families with international travel — visits to relatives abroad, attendance at ag trade events in Australia or Spain, ag-equipment sourcing trips to Mexico, or just a Mediterranean cruise booked months in advance — all need to address §7345 certifications before travel. The California FTB does not certify to the State Department but can independently affect California professional licenses (including ag-related licenses through CDFA and the Department of Pesticide Regulation) in certain circumstances.

No. The firm is headquartered at 1100 S. Robertson Boulevard in Los Angeles, but we represent clients throughout Glenn County by phone, secure document portal, and email. Glenn is a small county and the practice runs almost entirely remotely. Form 2848 routes IRS contact to counsel; FTB Form 3520 does the same on the state side. Document exchange happens through the secure portal; conferences happen by phone or Zoom; transcripts pull through CAF and TDS. Most Glenn County engagements never require an in-person meeting from start to finish. When in-person matters — an FTB headquarters conference at Rancho Cordova, a Tax Court trial at the Matsui Courthouse on I Street, a U.S. District Court appearance in the same building, an OTA hearing at 400 R Street, or a Glenn County Superior Court appearance at 526 W. Sycamore Street in Willows — we coordinate appropriately. Most files close without anyone leaving their property.

Yes. Communications between you and a California-licensed attorney for the purpose of seeking legal advice are protected by California Evidence Code §954 attorney-client privilege and the parallel federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to non-attorney CPAs and EAs but does not extend to criminal-tax matters. An attorney handling your tax case retains the broader privilege that survives criminal investigation.