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Tax Attorney in Mono County
Federal IRS and California state tax representation for taxpayers across Mono County — from the unincorporated county seat at Bridgeport on the Walker River, south through Bodie, Mono Lake and Lee Vining at the Tioga Pass gateway to Yosemite, down US-395 through June Lake, Crowley Lake, and McGee Creek, into Mammoth Lakes and its ski-resort economy, and out to the Owens River headwaters and the high-desert ranches along the Nevada line. Our California Bar-admitted attorneys handle IRS audits, FTB residency examinations triggered by the CA-NV state line a short drive from Bridgeport and across US-395 to Reno and Carson City, Mammoth Mountain ski-resort vacation-home Schedule E and IRC §280A 14-day analysis, Mammoth Lakes short-term-rental TOT and permit interplay with federal classification, Mono Lake-area conservation-easement and water-rights tax matters, U.S. Tax Court petitions designated to Sacramento, CDTFA determinations on Mammoth Village retail and Bridgeport main-street businesses, and EDD payroll audits across the seasonal Mammoth ski and summer-tourism workforce. Headquartered in Los Angeles at 1100 S. Robertson Boulevard, with phone and secure-portal coverage for every community in Mono County.
By Parham Khorsandi, Esq. — California Bar #266658. Admitted to practice before the United States Tax Court. Last Reviewed: .
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Mono County taxpayers facing IRS or FTB collection: three tax-controversy zones along US-395
Mono County stretches roughly 130 miles along the eastern Sierra crest from the Walker basin near the Nevada border in the north down through Bridgeport, Mono Lake, June Lake, Mammoth Lakes, and Crowley Lake to the Owens River headwaters and the Inyo County line, and the tax problems split along that corridor. First, Mammoth Lakes — the county's single incorporated town and the only urbanized concentration of population in the county — produces the heaviest volume of vacation-rental and ski-resort matters: Mammoth Mountain Ski Area operators and contractors, condo-and-cabin owners renting through VRBO and Airbnb during the December-through-April ski peak and the June-through-September summer hiking and fishing window, and seasonal restaurant and lodging payroll that runs in two compressed pulses with shoulder-season dead months in between. Second, the unincorporated US-395 north corridor — Bridgeport (population roughly 575, the county seat), Walker, Coleville, and the Antelope Valley ranches — carries a heavy ranching and agricultural-Schedule F profile, plus high-stakes FTB residency audits driven by the proximity of the Nevada state line at the Topaz Lake border crossing (a 25-minute drive north from Bridgeport on US-395). Third, the Mono Lake / Tioga Pass / Yosemite-east-entrance cluster — Lee Vining at the lake, the Tioga Road gateway communities, and the June Lake Loop — raises conservation-easement, water-rights, and federal-land-permit tax matters tied to Mono Lake Tufa State Natural Reserve, Inyo National Forest, and the Yosemite east-side concession economy.
$100M+
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2,000+
Tax cases resolved
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LA HQ, serving all of Mono County
Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.
A California firm representing Mono County taxpayers along the entire eastern Sierra US-395 corridor
Victory Tax Lawyers, LLP is a California-licensed tax-law firm with its principal office at 1100 S. Robertson Boulevard in Los Angeles. Both attorneys hold the State Bar of California license in active standing — Parham Khorsandi, Cal Bar #266658, and Amir Boroumand, Cal Bar #269570 — and both are admitted to practice before the United States Tax Court. Because we are California-admitted, we appear directly before the FTB, CDTFA, EDD, and the California Office of Tax Appeals on behalf of Mono County clients without a Form 2848 workaround or out-of-state co-counsel arrangement.
Mono County is one of the smallest California counties by population — roughly 13,000 year-round residents spread across about 3,000 square miles, the lowest population density in the state outside Alpine County. Only one community is incorporated: the Town of Mammoth Lakes, which holds roughly 7,200 of those residents. The county seat sits at Bridgeport, an unincorporated community of about 575 people along the Walker River. The other named places — Lee Vining at Mono Lake, June Lake on the June Lake Loop, Crowley Lake and McGee Creek, the historic gold-rush ghost town at Bodie State Historic Park, Walker and Coleville in the Antelope Valley, Tom's Place, and the high-desert ranches along the Nevada line — are all unincorporated. The county's full-time population is small, but the resident tax-controversy profile is amplified by a part-year and second-home population that swings the county's housing-unit count to a roughly 4-to-1 ratio of total housing units to occupied year-round units in Mammoth Lakes alone.
Four economic anchors shape the tax-controversy profile. First, the Mammoth Mountain Ski Area and the Mammoth Lakes ski-resort economy — lift operators and instructors, the village retail and food-and-beverage cluster, the dense short-term-rental inventory of condos and cabins from the Old Mammoth and Snowcreek neighborhoods up the Lake Mary Road corridor — drives vacation-home, IRC §280A 14-day rule, and Schedule E versus Schedule C classification matters that interact with the town's own short-term rental permit and TOT regime. Second, Yosemite National Park's eastern Tioga Pass entrance at Lee Vining and the Mono Lake Tufa State Natural Reserve generate park-concession, federal-permit, and conservation-easement tax matters from May through October each year (Tioga Pass closes for winter and reopens in late spring). Third, the high-desert ranching belt — Antelope Valley around Walker and Coleville, the Bridgeport Valley along the Walker River, and the Crowley Lake / Long Valley ranches near the Inyo line — produces Schedule F farm-and-ranch reporting, water-rights and grazing-permit transactions, and conservation-easement deductions under IRC §170(h). Fourth, the close proximity of the California-Nevada state line — Topaz Lake border crossing 25 minutes north of Bridgeport, and Reno-Tahoe-area population centers 90 minutes to two hours away — produces FTB residency-audit exposure on the same eastern-Sierra fact patterns that show up in Alpine and Inyo counties.
The rest of this page lays out the federal and California overlap as it applies to Mono County: the courthouses where these matters are heard, the Mono County Assessor and Treasurer-Tax Collector at the Annex II government center on Bryant Street in Bridgeport that handle local property-tax exposure, the IRS Taxpayer Assistance Center serving the county from Sacramento, and the specific federal and state pressure points that hit Mono County filers from Bridgeport to Mammoth Lakes.
Your tax rights as a Mono County taxpayer
Federal taxpayer rights are codified across the Internal Revenue Code and summarized in IRS Publication 1, the Taxpayer Bill of Rights. California layers its own taxpayer-rights regime on top, primarily through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel provisions for CDTFA and EDD. The major rights you can invoke in a Mono County tax matter:
Right to representation (federal)
Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview if you state you wish to consult an authorized representative. A signed Form 2848 puts your tax attorney between you and the IRS for the remainder of the matter. The IRS Sacramento Taxpayer Assistance Center on Watt Avenue — the closest TAC to most of Mono County via the long US-395-to-Highway-50 or US-395-to-I-80 route — honors this at the in-person counter, and the Reno TAC handles Mono filers who can drive over Monitor or Conway Summit to Nevada more easily than across the Sierra.
Right to representation (California)
FTB Form 3520-PIT (or 3520-BE for entities) appoints a representative with full authority before the Franchise Tax Board. CDTFA Form 392 and EDD DE 48 do the same for sales-tax and payroll matters. Once filed, all FTB Rancho Cordova headquarters notices route to counsel rather than to a Bridgeport P.O. box or a Mammoth Lakes condo.
Right to Collection Due Process
After a Notice of Federal Tax Lien (IRC §6320) or a Final Notice of Intent to Levy (IRC §6330), you have 30 days to request a Collection Due Process hearing on Form 12153. CDP requests pause federal collection enforcement and preserve U.S. Tax Court review.
Right to OTA appeal
Effective 2018 under AB 102, the California Office of Tax Appeals hears appeals from FTB, CDTFA, and EDD determinations. The appeal window is 30 days from the Notice of Action for FTB matters. Mono County cases are heard at OTA Sacramento at 400 R Street — a long drive from anywhere in Mono County, which makes telephonic and remote hearings common for eastern-Sierra appeals.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Mono County petitioners typically designate Sacramento as the place of trial — the Tax Court holds sessions at the Robert T. Matsui U.S. Courthouse at 501 I Street. Los Angeles at the Edward R. Roybal Federal Building is an alternative for filers in southern Mono County (Mammoth Lakes, Crowley Lake) who drive south on US-395 more readily than over the Sierra to Sacramento.
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).
Right to a California OIC
FTB has compromise authority under Cal. Rev. & Tax. Code §19443. CDTFA operates a parallel offer program under Cal. Rev. & Tax. Code §6832. EDD compromise authority sits at Cal. Unemp. Ins. Code §1192. Each program has its own form, financial-disclosure standard, and review track.
Right to a Collection Statute
IRC §6502 gives the IRS 10 years from assessment to collect. California's parallel period under Cal. Rev. & Tax. Code §19255 is 20 years — double the federal CSED. Pull both transcripts before negotiating.
How Victory Tax Lawyers helps Mono County taxpayers
Federal & California Offer in Compromise
We prepare and 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. Mammoth Lakes OIC files often turn on second-home equity treatment — a Reasonable Collection Potential figure on a ski-condo with five-to-eight years of post-2017 appreciation can swallow what would otherwise be an accepted federal offer. Bridgeport-area ranching files turn on grazing-rights and water-rights valuation, working-asset versus liquidation-asset analysis, and standing-livestock inventories. Conservation-easement carryforwards under IRC §170(h) on Antelope Valley or Long Valley ranch parcels add their own RCP layer.
Installment Agreements (IRS & FTB)
Streamlined IRS IAs under $50,000, Non-Streamlined IAs over $50,000 with Form 433-F disclosure, and Partial Pay Installment Agreements under IRC §6159 that run only through the CSED. FTB monthly-payment plans under FTB Form 3567. For a Mammoth Lakes household carrying mortgage payments on a Snowcreek or Old Mammoth primary plus a Bridgeport-area family ranch parcel or a Crowley Lake fishing cabin, the disposable-income math hinges on which expenses survive the IRS Allowable Living Expense tables — and the high-cost-of-living adjustment for the Mammoth Lakes / Bishop / eastern Sierra ALE region runs above the statewide average.
Lien release and withdrawal
A federal Notice of Federal Tax Lien under IRC §6321 and an FTB State Tax Lien under Cal. Gov. Code §7170 both attach to Mono County real and personal property and record at the Mono County Recorder in Bridgeport. We pursue release after payment, certificate of discharge for refinancing or sale, subordination, and lien withdrawal under the Fresh Start program for IAs under $25,000. A lien on a Mammoth Lakes condo or a Bridgeport-area ranch parcel can stall an escrow that has been months in the making, particularly during the narrow late-summer and shoulder-season sale windows that drive turnover in eastern-Sierra real estate.
Levy release (IRS, FTB, EDD)
Federal wage levies (CP90 / LT11) and bank levies under IRC §6331 stop with CNC, an accepted IA, an accepted OIC, or a CDP request. FTB Earnings Withholding Orders under Cal. Rev. & Tax. Code §18670 and bank levies under §18670.5 release under analogous resolutions. Mammoth Mountain ski-resort and Mammoth Lakes village paychecks run on seasonal cycles, and a wage levy that lands during the December-through-April ski peak or the June-through-September summer-tourism pulse can disrupt a household's only earning months — release timing matters more here than for year-round payroll.
Audit and exam defense
Federal correspondence, office, and field audits. FTB residency audits under Cal. Rev. & Tax. Code §17014 — routine after a Bridgeport-area filer relocates 25 minutes north across Topaz Lake to the Nevada side, or a Mammoth Lakes filer relocates to the Reno or Carson City corridor up US-395. CDTFA sales-tax audits on Mammoth Village restaurants and retail, Bridgeport main-street businesses, June Lake and Lee Vining seasonal hospitality. EDD AB 5 audits on ski-resort independent instructors, snow-school contractors, summer-fishing-guide operations on the Owens River and Crowley Lake, and Yosemite east-side concession contractors.
Penalty abatement
Federal First-Time Penalty Abatement and reasonable-cause requests under IRC §6651. FTB penalty waivers under Cal. Rev. & Tax. Code §19131 (failure to file) and §19132 (failure to pay), and CDTFA waivers under §6592. Reasonable-cause grounds for Mono County filers include record-setting Sierra snowpack winters that closed US-395 stretches and isolated communities for days at a time, atmospheric-river events that took out the Walker River and Owens River basin road network, summer wildfire smoke and evacuation episodes from the Mono Lake and June Lake areas, and the long-running Tioga Pass winter closure that cuts Mono County off from Yosemite Valley each year from November through May.
12 types of Mono County tax issues we handle
Federal and California state practice areas, framed for the matters that walk in the door from Mammoth Lakes, Bridgeport, Lee Vining, June Lake, Crowley Lake, and the eastern Sierra US-395 corridor.
Mammoth Lakes vacation-home Schedule E & §280A
A Mammoth Lakes ski-and-summer condo owner who personally uses the property over the holiday weeks, ski-week breaks, and August fishing window and rents the balance through Airbnb, VRBO, or a Mammoth-area property manager faces the Schedule E versus Schedule C question and the IRC §280A 14-day rule. Personal use exceeding 14 days or 10 percent of rental days converts the property to a residence with deduction limits. Mammoth Lakes' own short-term rental permit program and TOT collection add a parallel municipal layer that the IRS does not see but that documents personal-versus-rental use in town records the auditor can request — permit categories and night counts often line up directly against Schedule E figures.
Eastern-Sierra CA-NV residency shifts
The nine-factor domicile test under Cal. Rev. & Tax. Code §17014 and FTB Pub. 1031. A Bridgeport-area filer can be in Topaz Lake on the Nevada side in 25 minutes; a Mammoth Lakes filer can be in Reno in two-and-a-half hours up US-395 and in Carson City in two hours. The FTB regularly examines partial-year and departing-resident filings from Mono County, particularly when California-source income (Mammoth Mountain wages, California-titled rental property, FTB-registered LLC interests in ranch or development partnerships) continues post-move. Nevada has no state income tax, which makes the move financially significant for high earners but expensive in audit-defense terms if the facts don't support the position.
Mammoth Mountain seasonal payroll & TFRP
Under IRC §6672, the IRS pierces the corporate veil for unpaid payroll trust funds. Mammoth Village restaurants and lodging operators, June Lake and Lee Vining seasonal hospitality, Bridgeport-area ranching operations with seasonal labor, Yosemite east-side concession contractors, and Mammoth ski-school or snowboard-school subcontractors that fell behind on Form 941 deposits often discover this through Form 4180 interviews. EDD parallel exposure runs under Cal. Unemp. Ins. Code §1735 — doubly relevant here because of the two-pulse ski-and-summer payroll cycle.
EDD AB 5 worker-classification
Mammoth Mountain independent ski and snowboard instructors, summer-fishing-guide operators on the Owens River, Crowley Lake, and the eastern Sierra alpine lakes, Yosemite east-side concession contractors, Mono Lake and Bodie tour-guide operators, hospitality-cleaning pools across the Mammoth Lakes vacation-rental market, and Bridgeport-area trade subcontractors reclassified from 1099 to W-2 under the Dynamex ABC test codified at Cal. Lab. Code §2775. Back UI, ETT, SDI, and PIT withholding for three years plus penalties.
CDTFA cash-business audits
Mammoth Village restaurants and bars, Mammoth Mountain on-slope food-and-beverage operators, Bridgeport main-street restaurants and the Walker River-area saloons, Lee Vining tourist-stop operators at the Tioga gateway, June Lake village retail and lodging, and the US-395 corridor convenience-store cluster all draw CDTFA mark-up audits using observation tests and POS reconciliation. Mammoth's two-pulse seasonal economy — a December-through-April ski compression and a June-through-September summer surge with two largely-dead shoulder seasons — makes seasonal pull analysis a fact-intensive fight.
Eastern-Sierra ranching Schedule F
Antelope Valley ranches around Walker and Coleville, Bridgeport Valley cattle operations along the Walker River, and Long Valley / Crowley Lake-area ranches near the Inyo line file Schedule F farm income with the federal special rules for farmers and ranchers: IRC §179 and §168(k) depreciation on equipment, §1301 income averaging, §175 soil-and-water conservation expenses, §180 fertilizer election, and the special-use valuation under §2032A on farm-and-ranch estates. Federal grazing-permit and water-rights transactions add another layer.
Conservation-easement deductions
Bridgeport Valley, Antelope Valley, Long Valley, and the Mono Basin host conservation-easement transactions under IRC §170(h) that protect ranch and habitat parcels from development. The IRS has scrutinized syndicated easements heavily since the 2020s; individual ranch easements remain a legitimate planning tool but require appraisal substantiation under §170(f)(11) and Reg. §1.170A-13 that holds up on audit. Land trusts active in the eastern Sierra include the Eastern Sierra Land Trust and California Rangeland Trust.
Mono Lake water and conservancy matters
The Mono Lake Committee, Mono Basin Conservancy, and California State Lands Commission govern water-export and tufa-protection policy at Mono Lake. The Los Angeles Department of Water and Power's historical water exports under State Water Resources Control Board Decision 1631 (1994) and subsequent orders shape the federal-and-state tax position of any settlement payment, mitigation-fund distribution, or in-lieu compensation that touches Mono Basin water users. We work with the federal and California tax treatment of those transactions case-by-case.
Federal and California tax liens
NFTLs filed with the California Secretary of State and the Mono County Recorder in Bridgeport, and FTB State Tax Liens under Cal. Gov. Code §7170 et seq. Both cloud title on Mono County real property until released or withdrawn — a problem mid-escrow on a Mammoth Lakes condo sale or a Bridgeport-area ranch transfer, and particularly tight on the Mammoth ski-season closing window where the year's transaction volume compresses into a few months.
Passport revocation defense
IRC §7345 certifications to the State Department. We work to decertify before travel for Mono County residents with international family ties, Mammoth Mountain executives attending overseas ski-industry events, and Yosemite east-side concession executives with international project work.
Disaster-zone filing relief
Record-setting Sierra snowpack winters (2017, 2023) buried eastern-Sierra communities; the 2023 atmospheric-river sequence and subsequent flooding cut US-395 access in places and closed Mammoth Mountain operations for weeks; summer wildfire smoke from California and Nevada fires periodically forces Mono Lake and June Lake closures; the long-running Tioga Pass winter closure isolates the western side of the county each year. IRS disaster-relief postponements under IRC §7508A and FTB conformity extensions cover filing and payment deadlines for affected ZIP codes — but only inside the declared window, and only for documented disaster-zone filers. Penalty reasonable cause covers the gaps when the declared window does not.
Innocent Spouse Relief
Federal Form 8857 relief under IRC §6015 and California parallel relief under Cal. Rev. & Tax. Code §18533. California is a community-property state under Cal. Fam. Code §760 — the analysis is fact-heavy, especially in Mammoth Lakes households where one spouse runs a resort-economy business with seasonal cash swings the non-working spouse never saw on paper.
Nine common causes of tax debt in Mono County
1. Mammoth Lakes rental misclassification
A Mammoth Lakes ski-and-summer condo owner uses the property 30 nights per year and rents it 120 nights. The owner files Schedule E and deducts a full year of mortgage interest, property tax, depreciation, and operating expenses against rental income. The IRS reviews under IRC §280A and reclassifies the property as a personal residence, capping deductions and converting prior losses to ordinary income. The town's STR permit records often supply the auditor's personal-use evidence.
2. Departing-resident FTB audits
A Bridgeport-area rancher relocates to the Nevada side at Topaz Lake or a Mammoth Lakes operator moves to Reno or Carson City for the no-state-income-tax position. The FTB nine-factor domicile test routinely catches partial moves where the California ranch parcel, Mammoth condo, professional license, or California-source K-1 income continues post-move. The FTB asserts continued California domicile for one to three additional tax years; resolution turns on documentary proof of physical and economic relocation.
3. Resort-worker seasonal payroll gaps
A Mammoth Village restaurant or lodging operator stops depositing 941 trust funds during the shoulder seasons (April-to-June and October-to-November). The IRS asserts TFRP against the owner personally under IRC §6672, and EDD assesses parallel state payroll under Cal. Unemp. Ins. Code §1735. Bridgeport-area ranches with concentrated late-spring-through-fall payroll have the same pattern on a different calendar.
4. STR Schedule C reclassification
A Mammoth Lakes owner running a small-inn-style short-term rental with daily cleaning, on-site concierge, breakfast, or guided activity packages files Schedule E. The IRS asserts — supported by the STR market's increasingly hotel-like service expectations — that the operation belongs on Schedule C with full self-employment tax. The reclassification adds 15.3 percent SE tax on the net rental income for years going forward.
5. Vacation-home capital-gain miscalculation
A southern California or Bay Area filer who used a Mammoth Lakes condo or a June Lake cabin as a vacation home for 20 years sells without a Section 121 exclusion (the property was never a primary residence). Long-term capital gain at 23.8 percent federal (20 percent plus 3.8 percent net investment income tax) plus 13.3 percent California, against an inflation-driven basis from an early-2000s purchase, can produce a tax bill that surprises the seller at closing.
6. Conservation-easement valuation disputes
A Bridgeport Valley or Long Valley rancher takes a conservation-easement deduction under IRC §170(h) supported by a qualified-appraiser valuation. The IRS challenges the before-and-after value calculation and recharacterizes a portion as overvaluation, triggering accuracy-related penalty under IRC §6662(h) gross-valuation-misstatement penalty rates. Eastern Sierra Land Trust and California Rangeland Trust easements with rigorous baseline documentation hold up better than thinly-supported deductions.
7. Crypto trading without records
Mammoth Lakes resort-economy households with technology overflow exposure and remote-worker arrivals from the Bay Area carry meaningful crypto positions. Exchanges issued 1099-K and 1099-MISC reports; the IRS matches them to filed returns and issues CP2000 notices for the gap. FTB pursues the parallel California assessment using the federal data.
8. Disaster-disrupted filing
Filers affected by the 2023 atmospheric-river sequence and record snowpack winter, by US-395 closure events, by Tioga Pass winter isolation, or by Mono Basin and June Lake wildfire-smoke evacuation episodes missed deadlines. Disaster-zone extensions under IRC §7508A help, but penalty stacks accumulate fast when the disaster window lapses or the filer's ZIP code falls outside the postponement list.
9. AB 5 instructor reclassification
Mammoth Mountain independent ski and snowboard instructors and summer-fishing-guide operations across Crowley Lake, the Owens River, and the eastern Sierra alpine lakes were historically engaged as 1099 contractors. EDD AB 5 reclassification under Cal. Lab. Code §2775 sweeps these workers onto employer payrolls, with back UI, ETT, SDI, and PIT withholding plus penalties across the look-back window.
Who is on the hook: eight Mono County tax-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 spouse can be pursued for the entire balance — even after divorce — subject to Innocent Spouse Relief under IRC §6015 and Cal. Rev. & Tax. Code §18533. Especially relevant in Mammoth Lakes households where one spouse operates a resort-economy business with year-end cash swings the other never saw on a current bank statement.
Partnership general partners
Under IRC §6231 and the BBA centralized partnership audit regime, general partners of Mono County ranching partnerships, Mammoth Lakes vacation-rental syndicates, June Lake or Bridgeport-area development partnerships, and Crowley Lake or Owens River fishing-operation LPs face imputed underpayment liability for partnership-level adjustments. Push-out elections under IRC §6226 shift the burden to the partners' year of audit.
Responsible persons for payroll
Trust Fund Recovery Penalty under IRC §6672 reaches anyone with check-signing authority who willfully failed to pay over withheld taxes. State parallel sits at Cal. Unemp. Ins. Code §1735 for EDD payroll. Reaches Mammoth Lakes, Bridgeport, Lee Vining, and June Lake small-business owners after the entity folds — particularly common in the seasonal Mammoth hospitality sector and the two-pulse ski-and-summer ranching calendar.
CDTFA dual-determinations
CDTFA issues dual-determination notices personally against corporate officers, directors, and LLC members of entities that fail to remit sales tax in trust, under Cal. Rev. & Tax. Code §6829. Common against Mammoth Village restaurant operators, Bridgeport main-street businesses, Lee Vining tourist-stop operators, and June Lake retail and lodging entities after the business closes.
FTB suspended-entity personal exposure
An entity that fails to pay California minimum franchise tax or file a Statement of Information is suspended by FTB under Cal. Rev. & Tax. Code §23301. While suspended, the entity loses its right to contract, sue, or defend in California courts — including the Mono County Superior Court North County Branch in Bridgeport and the South County Branch in Mammoth Lakes. Officers signing on behalf during suspension can incur personal exposure.
Transferee liability
IRC §6901 reaches a transferee of assets where the transfer rendered the transferor insolvent and tax debts remain unpaid. Mono County family-LLC restructurings, Prop 19 parent-to-child transfers under Cal. Const. Art. XIII A on Mammoth Lakes primary homes, intra-family Bridgeport-Valley and Antelope-Valley ranch successions, and Mammoth or June Lake vacation-property gift transfers can all trigger this analysis.
Successor business liability
Asset purchases of a Mammoth Village restaurant, a Mammoth Lakes lodging operation, a Bridgeport main-street business, a Lee Vining tourist stop, or a June Lake retail or lodging operator can carry forward CDTFA sales-tax successor liability under Cal. Rev. & Tax. Code §6811-6814 and EDD payroll successor liability under Cal. Unemp. Ins. Code §1731. Clearance letters from CDTFA and EDD before close are the buyer's protection — particularly important on Mammoth-area and seasonal-hospitality asset purchases where cyclical cash-flow swings hide 941 lapses.
Estate and decedent returns
California has no state estate tax; the decedent's final 1040 and the estate's 1041 are the executor's responsibility. Personal liability for the executor attaches under 31 USC §3713(b) if distributions are made before federal tax claims are satisfied. Probate of Mono County estates — including high-value Mammoth Lakes condo and lakefront properties, multi-generation Bridgeport-Valley and Antelope-Valley ranch holdings, and June Lake cabins — moves through the Mono County Superior Court Probate Division at the Bridgeport courthouse.
What resolution can look like in Mono County
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 — the same compromise unit handles Mono County files out of FTB headquarters in Rancho Cordova. 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 while finances stabilize.
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 record-setting Sierra snowpack winters, US-395 closure events, Tioga Pass winter isolation, Mono Basin wildfire smoke and evacuation episodes, serious illness, and preparer reliance. FTB waivers under §19131 and §19132 follow parallel principles.
Liens and levies released
A federal NFTL withdraws once a streamlined IA is in place under Fresh Start. FTB State Tax Liens release on payment, accepted compromise, or release-for-cause — critical when refinancing or selling Mono County real property, and particularly time-sensitive on Mammoth Lakes and Bridgeport seasonal escrows. Wage and bank levies stop when the account moves to CNC, IA, or OIC processing. Passport certifications reverse once federal debt drops below the §7345 threshold.
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 Mono County tax matter
Mono County taxpayers deal with two tax systems that interact in ways most out-of-state firms do not understand — and a third layer of complication arrives at the California-Nevada state line just north of Bridgeport and within a two-hour drive of Mammoth Lakes. A Mammoth Lakes household with resort-economy income, a short-term-rental condo, and a Bridgeport-area family ranch interest can have FTB residency exposure on one tax year, federal IRC §280A and Schedule E versus Schedule C exposure on another, and Schedule F farm-income exposure on a third — with the Nevada-side comparable income at Reno or Carson City sitting beyond California's reach entirely. A federal NFTL filed with the Mono County Recorder in Bridgeport sits in the same recording index as the FTB's own State Tax Lien against the same Mammoth or Bridgeport property. The matters do not stay in their lanes.
Victory Tax Lawyers is California-admitted, headquartered in Los Angeles, and built around exactly this overlap. Parham Khorsandi (Cal Bar #266658) and Amir Boroumand (Cal Bar #269570) appear directly before the FTB, CDTFA, EDD, and the California Office of Tax Appeals, and on the federal side before the IRS and the U.S. Tax Court. No out-of-state coordination, no Form 2848 workaround. The same attorneys handle the whole engagement from initial Form 12153 through final Tax Court trial in Sacramento or Los Angeles.
California is one of the most lawyer-intensive tax environments in the country. The State Bar's Rule of Professional Conduct 7.1 (formerly Rule 1-400) tightly 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, which is why this page does not promise outcomes, does not promote dollar averages without context, and does not list testimonials without proper disclosure.
Mono County is also distinctive for the practice mix the geography produces. The Mammoth ski-resort STR matters, eastern-Sierra ranching Schedule F files, conservation-easement deductions on Antelope Valley and Long Valley parcels, Mono Lake water-and-conservancy matters, and CA-NV residency cases that show up here are not the same matters that walk in the door in San Diego or Los Angeles. That practice density shapes how we approach a Mono County engagement.
The seven steps of a VTL tax-resolution engagement
Free consultation
A 30-minute call with an attorney to outline the facts, the IRS or FTB notices received, and the realistic resolution options for a Mono County matter.
Engagement letter
A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law attorney-client privilege both attach.
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. All notices route to counsel.
Transcript investigation
IRS Account Transcripts, Wage-and-Income Transcripts, and Record of Account pulled across all open years. FTB MyFTB account, CDTFA records, and EDD records pulled. Federal CSED and California 20-year statute dates verified.
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.
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.
Compliance close-out
Post-resolution monitoring: quarterly estimates, return filings, and protection against IA default on either side. 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 generally has ten years from the date of assessment to collect a tax. After the federal Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Tolling events that extend the federal CSED include a pending Offer in Compromise (extends by OIC pendency plus 30 days), bankruptcy filing (extends by bankruptcy stay plus six months), Collection Due Process hearings (extends while pending), 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 the assessment, the date the liability becomes due and payable, or the date a final return was filed, to collect. That is double the federal CSED. CDTFA collection statutes for sales-and-use tax are governed by Cal. Rev. & Tax. Code §6711, generally 10 years from determination but with similar tolling. EDD has its own collection window under Cal. Unemp. Ins. Code §1701.
The practical impact for a Mono County filer: a federal balance assessed in 2016 may be approaching 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. For Mono filers who have since moved across the line to Nevada — whether to the Topaz Lake side just north of Bridgeport, or to Reno, Carson City, or Las Vegas — the FTB tail still attaches to California-source income earned during the years of California residency. The move forward does not erase the look-back.
Mono County venue: where federal and state tax matters are heard
Mono County's tax-controversy venues are split between distant federal districts and the county's own state courts at Bridgeport and Mammoth Lakes. The U.S. Tax Court designates Sacramento as the primary place of trial for the Eastern District side of California; Los Angeles at the Edward R. Roybal Federal Building is the southern alternative for filers in Mammoth Lakes and Crowley Lake. The U.S. District Court for the Eastern District of California sits in Sacramento; Central District of California sits in Los Angeles. The Mono County Superior Court operates two branches under one court: the North County Branch at Bridgeport (the county seat) and the South County Branch in Mammoth Lakes. State matters at the FTB, CDTFA, and EDD that reach a formal appeal proceed through the California Office of Tax Appeals at its Sacramento hearing location at 400 R Street — with telephonic and remote hearings common for eastern-Sierra appellants given the driving distance.
U.S. Tax Court — Sacramento and Los Angeles
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. Los Angeles is the southern alternative at the Edward R. Roybal Federal Building, 255 E. Temple Street, Los Angeles 90012. Mono County petitioners commonly designate Sacramento, though Mammoth Lakes and southern Mono filers sometimes designate Los Angeles given the US-395-south route through Bishop, Lone Pine, and the Owens Valley. Sessions are calendared several times per year at each location.
IRS Taxpayer Assistance Center — Sacramento
The IRS Sacramento Taxpayer Assistance Center at 4330 Watt Avenue, Sacramento 95821 is the nearest TAC inside California for Mono County, serving Bridgeport, Mammoth Lakes, and the eastern Sierra corridor. Appointments are required and arranged through apps.irs.gov/app/office-locator or 844-545-5640. The TAC handles in-person account inquiries, payment intake, identity verification, and ITIN applications. Many Mono County filers find the Reno, Nevada TAC easier to reach via US-395 north, particularly when Tioga Pass and the Sierra crossings are restricted; the Reno TAC honors federal-form intake regardless of taxpayer state.
Mono County Treasurer-Tax Collector
The Mono County Treasurer-Tax Collector at the Annex II, 25 Bryant Street, Bridgeport 93517 (P.O. Box 495) administers Mono County property-tax billing, collection, defaulted-property auctions, and unsecured-roll collections. Property-tax delinquencies on Mono County real property — including those triggered by Prop 13 reassessment changes on Mammoth Lakes condos, Bridgeport-Valley and Antelope-Valley ranch parcels, and June Lake or Crowley Lake cabins — route through this office.
Mono County Assessor
The Mono County Assessor at the Annex II, 25 Bryant Street, Bridgeport 93517 (P.O. Box 456) sets Prop 13 base-year value and annual assessed value for every parcel in the county. Prop 19 parent-to-child reassessment exclusions, Prop 8 decline-in-value applications, and assessment appeals to the Mono County Assessment Appeals Board start here. The Assessor's office shares the Annex II government center with the Treasurer-Tax Collector, which makes parallel property-tax matters efficient for in-person resolution.
Mono County Superior Court — two branches
The Mono County Superior Court operates a North County Branch at 278 Main Street, Bridgeport 93517 and a South County Branch at 100 Thompson Way, Mammoth Lakes 93546. The court handles state-tax civil actions, FTB and CDTFA collection litigation, judicial review of OTA decisions, probate proceedings with tax components, and divorce matters involving community-property tax allocation. Both branches share a single court administration; calendar items can be assigned to either branch based on convenience.
FTB headquarters — Rancho Cordova
The California Franchise Tax Board headquarters at 9646 Butterfield Way, Rancho Cordova 95827 administers FTB collection and audit infrastructure for the state. Personal-income-tax audits, residency examinations under Cal. Rev. & Tax. Code §17014, corporate franchise-tax matters, and the §19443 compromise unit all sit on this campus. Mono County matters typically run by telephone, mail, and the MyFTB portal — in-person FTB meetings for eastern-Sierra cases are uncommon.
U.S. District Court — Eastern and Central Districts
Mono County sits inside the U.S. District Court for the Eastern District of California; the closest federal courthouse is the Robert T. Matsui U.S. Courthouse at 501 I Street, Sacramento 95814 (the same building that houses Tax Court Sacramento sessions). Some federal-tax matters involving Mono County defendants are also venued in the Central District of California in Los Angeles when the underlying conduct or witnesses sit south. Appellate review goes to the U.S. Court of Appeals for the Ninth Circuit in San Francisco.
California Office of Tax Appeals
The California Office of Tax Appeals was created in 2018 under AB 102 to hear appeals from FTB, CDTFA, and EDD determinations. Mono County matters are heard at OTA Sacramento at 400 R Street, with remote-hearing options that work well for eastern-Sierra appellants given the eight-to-twelve-hour round-trip drive from Mammoth Lakes or Bridgeport. Three-judge panels of Administrative Law Judges; decisions are precedential and published.
VTL represents clients in the one incorporated town of Mono County — Mammoth Lakes — and across the unincorporated communities including Bridgeport, Lee Vining, June Lake, Crowley Lake, McGee Creek, Tom's Place, Walker, Coleville, Topaz, Aspen Springs, Chalfant, Benton, Paradise, Long Valley, Mono City, and the Mono Lake Tufa State Natural Reserve gateway, along with the Bodie State Historic Park area and the Antelope Valley ranching communities.
Request a free consultation with a Mono County tax attorney
A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, your last filed federal and California returns, any Schedule E paperwork for a Mammoth Lakes vacation rental, any Schedule F farm reporting for a Bridgeport-Valley or Antelope-Valley ranch, any K-1s from June Lake or Crowley Lake partnership interests, any conservation-easement appraisal or substantiation if you have taken an IRC §170(h) deduction, the town of Mammoth Lakes STR permit if applicable, and any FTB, CDTFA, EDD, or Mono County Treasurer-Tax Collector correspondence. We will tell you which resolution options actually fit your facts — on both the federal and California sides — before you sign anything.
Office: 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Serving the Town of Mammoth Lakes plus every unincorporated community in Mono County by phone, secure portal, and in-person by appointment.
Frequently asked questions for Mono County taxpayers
Reviewed by
Parham Khorsandi, Esq.
Managing Attorney · California Bar #266658 · Admitted to the United States Tax Court
Parham Khorsandi is the managing attorney of Victory Tax Lawyers, LLP, headquartered at 1100 S. Robertson Boulevard in Los Angeles. His practice focuses on federal and California tax controversy, including Offer in Compromise negotiations before the IRS and FTB, Installment Agreements, Trust Fund Recovery Penalty defense, FTB residency audits, short-term-rental Schedule E versus Schedule C classification, ski-resort and vacation-rental IRC §280A analysis, eastern-Sierra ranching Schedule F matters, conservation-easement substantiation, CDTFA sales-tax representation, EDD worker-classification audits, OTA appeals, and litigation before the U.S. Tax Court Sacramento and Los Angeles sessions. He has represented Mono County individuals and businesses across Mammoth Lakes, Bridgeport, Lee Vining, June Lake, Crowley Lake, and the eastern Sierra US-395 corridor.
Last Reviewed:
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, the Mono County Treasurer-Tax Collector, the Mono County Assessor, 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), Mono County property-tax matters, and federal IRS / U.S. Tax Court matters are handled directly by the firm. Consult a licensed attorney about your specific situation before acting on any content on this page. The State Bar of California Rule of Professional Conduct 7.1 requires that lawyer communications not be false or misleading; this page strives to comply with that rule and does not promise specific outcomes.
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