Tax Attorney in Inyo County

Yes — in Sacramento and Los Angeles. The U.S. Tax Court designates Sacramento (Robert T. Matsui U.S. Courthouse, 501 I Street) and Los Angeles (Edward R. Roybal Federal Building, 255 E. Temple Street) as places of trial under Tax Court Rule 140. From Bishop, Sacramento is about seven hours north on U.S. 395 and U.S. 50; from Lone Pine or Independence, Los Angeles is about four-and-a-half hours south on U.S. 395 and CA-14. Most Inyo petitioners designate Los Angeles for the shorter drive and the more frequent LA calendar. Sessions are calendared several times per year at both locations.

The Treasurer-Tax Collector and the Assessor share the county-government complex at 168 N. Edwards Street, Independence 93526 — the same campus as the Superior Court. 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 Inyo 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, Prop 8 decline-in-value applications, and the recurring possessory-interest assessments on improvements built on LADWP-leased ground under Cal. Rev. & Tax. Code §107 all route through the Assessor.

Two layers apply. First, the IRC §280A 14-day rule: if your personal use exceeds the greater of 14 days or 10 percent of total rental days, the property is treated as a residence and rental deductions are capped at rental income (no net loss). Second, the Schedule C versus Schedule E character question: a true short-term-rental operation providing substantial services (cleaning between every stay, linens, breakfast, on-call host) can rise to a Schedule C trade or business with self-employment tax under IRC §1401; a passive rental with limited services stays on Schedule E. Inyo's Mount Whitney climbing-season peak (typically May through October) often concentrates rental nights, which makes the day-counting math fact-intensive. The Inyo County Treasurer-Tax Collector also collects transient-occupancy tax on STR stays in unincorporated areas; the city of Bishop has its own TOT ordinance. Get both the federal day-counting and the local TOT compliance right from day one — the IRS, the FTB, and the Inyo TTC each can reach the same property from a different angle.

Per-capita distributions of gaming-revenue net income from a tribal gaming operation (here, the Bishop Paiute Palace Indian Gaming Hall) are taxable as federal income to the recipient under the Indian Gaming Regulatory Act, 25 USC ch. 29, and the IRS regulations at Rev. Proc. 2011-56. The distribution is generally reported on Form 1099-MISC by the tribe. California state income tax generally does not apply to income earned by an enrolled member from sources within the Indian country of the member's own tribe (FTB Notice 89-1186, applying McClanahan v. Arizona State Tax Commission) — but the distribution remains federally taxable. Separately, individual-trust-allotment income from allotted land held in trust by the United States is exempt from federal income tax under the General Allotment Act of 1887 and Squire v. Capoeman, 351 U.S. 1 (1956). IRC §7873 exempts certain treaty-recognized fishing-rights-related income. The character of each receipt — per-capita, wages, allotment income, fee-land rent, treaty-rights income — drives the federal-tax treatment, and getting the categorization right is the whole game.

It depends on the facts, but this is a common Owens Valley snowbird fact pattern and yes, the FTB does examine it. The nine-factor domicile test under Cal. Rev. & Tax. Code §17014 looks at where your life is actually centered — primary home, vehicles, voter registration, driver's license, professional licenses, family ties, bank accounts, medical and dental care, and the location of your spouse and dependents. A retiree who keeps a Bishop home year-round, registers vehicles in California, votes in Inyo County, banks at the Bishop credit union, and sees doctors at Northern Inyo Hospital, while wintering in a Pahrump RV park or a Yuma manufactured-home park, is almost certainly a California resident regardless of the months-on-each-side count. Conversely, a retiree who moves the primary residence to Pahrump or Yuma, sells or rents out the Bishop home, registers vehicles in Nevada or Arizona, switches voter registration and driver's license, and treats the Inyo property as vacation-only can argue out-of-state domicile — but every fact matters and documentation needs to be in place before the audit notice arrives, not after.

Several pieces interact. The Los Angeles Department of Water and Power owns approximately 250,000 acres in the Owens Valley dating to the 1905-1913 aqueduct land purchases and leases parcels back to local ranchers under multi-year grazing-and-haying contracts. On the federal side, you operate a Schedule F farm; your basis is in the leasehold improvements (fences, corrals, irrigation systems, equipment) and in inventory, not in the underlying ground. Section 179 depreciation, Section 175 conservation expense, farm-income averaging under IRC §1301, and the IRC §183 hobby-loss rule all apply normally to the operating activity. On the property-tax side, the underlying LADWP parcel is exempt from local property tax as a public-entity holding under Cal. Rev. & Tax. Code §202 — but improvements you build on the leased ground may be assessed as a possessory interest under Cal. Rev. & Tax. Code §107, taxable to you as the lessee. On the estate side, your IRC §1014 stepped-up basis applies to the leasehold improvements and to fee-simple holdings, but not to the LADWP-owned ground (you never owned it). Get the lease history, the improvement schedule, and the possessory-interest assessment correspondence pulled together before any sale, transfer, or estate planning move.

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 seven hours northwest of Bishop. 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 for property-rich, cash-poor Inyo County households with fee-simple Owens Valley parcels or Eastern Sierra cabins.

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. An Inyo 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 income from STR rentals, Eastern Sierra outfitter activity, or LADWP-leased ranch operations survives a move to Nevada, Arizona, or elsewhere.

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 Inyo County small business — say, a Main Street Bishop restaurant, a Lone Pine outfitter, or a Death Valley gateway lodge — 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 Main Street Bishop restaurant, a U.S. 395 corridor gas-and-grocery at Independence or Lone Pine, a Mount Whitney pack-station guide service, or a Death Valley gateway lodge that closes with unpaid 941s, the owner usually faces all three exposures simultaneously.

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. Inyo residents traveling overseas for family visits, retired LADWP engineers with international travel plans, Eastern Sierra mountaineering guides leading international expeditions, and Death Valley film-and-photography location operators working international shoots 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 in certain circumstances.

No, and this is part of how the Inyo practice works. The firm is headquartered at 1100 S. Robertson Boulevard in Los Angeles, but we represent clients throughout Inyo County by phone, secure document portal, email, and video conference. Every Inyo engagement is structured to be handled remotely — Form 2848 puts federal authority in our hands, FTB Form 3520-PIT puts the California-side authority in our hands, and Inyo's geographic isolation (eight hours from Sacramento, four-and-a-half hours from LA at the closest point) means in-person meetings are neither expected nor practical. When in-person matters arise — an FTB headquarters conference at Rancho Cordova, a Tax Court trial in LA or Sacramento, a U.S. District Court appearance, an OTA hearing, or an Inyo County Superior Court appearance at the Independence Courthouse — we appear, and you generally do not need to travel.

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.