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Tax Attorney in Mountain View, California
What this page covers:
- Federal IRS and California FTB representation for Google, Intuit, Microsoft Silicon Valley, LinkedIn, and NASA Ames employees in Mountain View
- Google GSU and pre-Google ISO AMT-trap matters, IRC §1202 QSBS audit defense, IRC §83(b) elections, and IRC §409A deferred-comp problems
- Post-2020 FTB residency audits on Mountain View departures to Austin, Reno, Bellevue, Boise, and Phoenix
- FBAR and Form 8938 disclosure for the Indian-American, Chinese-American, Taiwanese-American, and Korean-American H-1B and L-1 workforce
- Santa Clara County property-tax appeals, U.S. Tax Court petitions designated to San Francisco or San Jose, and U.S. District Court Northern District of California San Jose Division matters
Mountain View tax controversy looks unlike most California cities because the Googleplex at 1600 Amphitheatre Parkway, the Charleston East and Bay View Google campuses, Intuit headquarters on Coast Avenue, Microsoft Silicon Valley on La Avenida, NASA Ames Research Center at Moffett Federal Airfield, and the LinkedIn cluster on the Sunnyvale border sit inside an 11-square-mile city of about 80,000 residents. The matters that come through this office reflect that density: Alphabet GSU under-withholding, pre-Google ISO AMT exposure, IRC §1202 QSBS positions, IRC §83(b) election protection, FBAR and Form 8938 disclosure, U.S.-India and U.S.-China treaty coordination, FTB residency audits on post-2020 Google relocations to Austin, Reno, Bellevue, and Boise, Santa Clara County property-tax assessment appeals on Old Mountain View, Cuesta Park, Whisman, Rex Manor, and Sylvan Park parcels, and CSFRA-affected Schedule E rental matters. Both managing attorneys hold the California Bar in active standing and are admitted to the United States Tax Court.
By Parham Khorsandi, Esq. — California Bar #266658. Admitted to the United States Tax Court. Last Reviewed: .
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This page explains how our California Bar-admitted firm represents Mountain View taxpayers across IRS, FTB, CDTFA, EDD, OTA, U.S. Tax Court, and the Santa Clara County Assessment Appeals Board. The work centers on the Google equity-compensation pipeline, the NASA Ames federal-civilian profile, the Intuit and Microsoft Silicon Valley equity packages, the FTB closer-connection audits that follow post-2020 departures, and the FBAR and Form 8938 caseload across the city’s Asian-American H-1B and L-1 workforce.
Cal Bar Admitted
Verifiable license #266658
U.S. Tax Court
Federal trial admission
BBB Accredited
A+ rating
5.0 / 72 Reviews
Google Business Profile
Mountain View taxpayers facing IRS or FTB action: a Google-anchored caseload built on GSU vests, pre-Google ISO AMT, §1202 QSBS, U.S.-India and U.S.-China FBAR exposure, NASA Ames federal-civilian filings, post-2020 departing-resident audits, and Santa Clara County property assessments
Mountain View has roughly 80,000 residents and hosts the global headquarters of Alphabet (Google), the global headquarters of Intuit, the Microsoft Silicon Valley research campus, NASA Ames Research Center at Moffett Federal Airfield, the LinkedIn presence on the Sunnyvale border, and a startup ecosystem along Castro Street, Villa Street, and Shoreline Boulevard. The tax-controversy mix sits on five anchors. First, the Google equity-compensation complex: the Googleplex at 1600 Amphitheatre Parkway, Charleston East, the Bay View campus, the Shoreline Boulevard buildings, and the Charleston Road sites together produce one of the densest concentrations of GSU vests, pre-Google ISO exercises with Alternative Minimum Tax preference under IRC §56(b)(3), and pre-IPO equity positions from acquired startups in the country. Second, IRC §1202 Qualified Small Business Stock from the venture-backed startup ecosystem that originates in and around the Google-engineer-founded company pipeline. Third, FBAR and Form 8938 disclosure exposure for the Indian-American, Chinese-American, Taiwanese-American, Korean-American, and Vietnamese-American H-1B and L-1 workforce. Fourth, the NASA Ames Research Center civilian-employee filings under Title 5 of the U.S. Code, FERS basic annuity, TSP, and intergovernmental personnel detail tax patterns. Fifth, post-2020 FTB residency audits on Mountain View Google, Intuit, Microsoft, and LinkedIn employees who relocated to Austin, Reno, Sparks, Bellevue, Redmond, Boise, Meridian, and Phoenix and now face multi-year examinations under R&TC §17014.
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Total tax relief secured
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Tax cases resolved
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CA-Based
LA HQ, serving all of Mountain View
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 Mountain View taxpayers across IRS, FTB, CDTFA, EDD, OTA, and the Santa Clara County Assessment Appeals Board
Victory Tax Lawyers, LLP is a California-licensed tax-law firm with its principal office at 1100 S. Robertson Boulevard in Los Angeles. Both managing 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 the firm is California-admitted, we appear directly before the FTB, CDTFA, EDD, and the California Office of Tax Appeals on behalf of Mountain View clients without a Form 2848 workaround or out-of-state co-counsel arrangement. On the federal side, we appear in U.S. Tax Court trial sessions in San Francisco at the Phillip Burton Federal Building (450 Golden Gate Avenue) and periodic San Jose sessions at the Robert F. Peckham Federal Building (280 S. 1st Street), and in the U.S. District Court for the Northern District of California San Jose Division at the same Peckham building, ten miles southeast of the Googleplex at 1600 Amphitheatre Parkway.
Mountain View is a city of approximately 80,000 residents on the mid-Peninsula, bordered by Palo Alto and Los Altos to the northwest, Sunnyvale to the east, Cupertino to the southeast, and Los Altos Hills to the south. The city covers roughly 12 square miles and sits at the intersection of U.S. Route 101, State Route 85, El Camino Real, and Central Expressway. The urban geography splits among the Google campus footprint in North Bayshore (the Googleplex at 1600 Amphitheatre Parkway, the Charleston East campus, the Bay View campus, the Shoreline Boulevard and Charleston Road buildings); the Intuit world headquarters at 2700 Coast Avenue; the Microsoft Silicon Valley campus at 1065 La Avenida; NASA Ames Research Center and Moffett Federal Airfield on the city’s eastern flank; the Castro Street downtown corridor with the Caltrain Mountain View station, City Hall at 500 Castro Street, and the Mountain View Center for the Performing Arts; the El Camino Real commercial spine; the El Camino Health Mountain View hospital campus; and the residential cores in Old Mountain View, Cuesta Park, Rex Manor, Sylvan Park, Whisman, Monta Loma, Waverly Park, North Whisman, Slater, and Willowgate. Mountain View Whisman School District and Mountain View-Los Altos Union High School District anchor the public-school ecosystem alongside Saint Francis High in Mountain View itself.
Five economic and demographic anchors shape the Mountain View tax-controversy profile. First, the Alphabet (Google) equity-compensation complex. Google’s headquarters campus in the North Bayshore area of Mountain View hosts tens of thousands of full-time employees across the Googleplex, Charleston East, the Bay View campus that opened in 2022, and the surrounding Charleston Road and Shoreline Boulevard buildings. The Google Stock Unit (GSU) is Alphabet’s primary equity vehicle, settled in Class A (GOOGL) or Class C (GOOG) shares. The vesting cycles, supplemental-withholding gaps, and basis-tracking errors on the post-2020 Alphabet 20-for-1 stock split create a recurring caseload that Mountain View shares with Sunnyvale and Cupertino but at a higher employee density than anywhere else in the city. Alphabet does not run a traditional IRC §423 ESPP with a lookback discount; the equity is structured around GSU grants rather than payroll-deduction purchases, which simplifies one corner of the analysis and complicates another.
Second, IRC §1202 Qualified Small Business Stock. The Google-alumni founder pipeline and the broader Mountain View startup ecosystem along Castro Street, Villa Street, and Shoreline Boulevard produce a steady flow of QSBS positions. Engineers and product managers who leave Google to start C-corporation companies, hold the original-issuance stock through the five-year IRC §1202(b) hold, and then sell on a strategic acquisition or IPO can exclude up to the greater of $10 million or 10x basis on the federal side. The traps are dense: the active-business requirement under §1202(e), the $50 million gross-asset cap at issuance, the redemption rules of §1202(c)(3), the working-capital limit, the LLC-conversion-to-C-corporation timing under IRC §351, and the federal-versus-California conformity gap (California decoupled from §1202 in 2013 under R&TC §17152, so the exclusion is federal-only).
Third, the foreign-account disclosure caseload across the Indian-American, Chinese-American, Taiwanese-American, Korean-American, and Vietnamese-American visa-holder community. Mountain View’s Asian-American population is concentrated in the Whisman, North Whisman, Slater, Sylvan Park, and Waverly Park neighborhoods, as well as the apartment stock along El Camino Real, Castro Street, and the Charleston Road corridor near Google. The Indian-American community carries NRE rupee accounts, NRO accounts, demat brokerage accounts, PPF and EPF retirement accounts, and inherited-property income that aggregates to the FBAR (FinCEN Form 114) reporting threshold under 31 USC §5314 and the Form 8938 (FATCA) threshold under IRC §6038D. The Chinese-American, Taiwanese-American, Korean-American, and Vietnamese-American communities carry parallel exposure on China, Hong Kong, Taiwan, Korea, and Vietnam accounts. The Streamlined Filing Compliance Procedure is the most common resolution path for non-willful past noncompliance.
Fourth, the NASA Ames Research Center civilian-employee profile. NASA Ames at Moffett Federal Airfield employs federal civilian researchers, engineers, and administrative staff under Title 5 of the U.S. Code. The Federal Employees Retirement System (FERS) coordinates a §401(a) basic annuity, Social Security, and the Thrift Savings Plan (TSP). The Intergovernmental Personnel Act detail program brings university and private-sector researchers onto NASA payroll temporarily, with dual-status filing complications. Security clearances at Ames affect the documentation footprint for a Schedule C side practice or §174 research-and-experimental-expenditure capitalization analysis. The TSP loan-and-withdrawal rules and the §72(t) 10-percent early-withdrawal additional tax create their own balance-due problems on a separation from federal service before age 55. Moffett Federal Airfield, jointly used by NASA, the California Air National Guard 129th Rescue Wing, and Google’s lease tenant Planetary Ventures, adds a layer where civilian, military, and private-sector tax patterns overlap in the same physical complex.
Fifth, the post-2020 departing-Mountain-View-employee FTB residency-audit caseload. The pandemic-era and post-pandemic remote-work shift drained a substantial cohort of Mountain View-based Google, Intuit, Microsoft, and LinkedIn employees to Austin, Texas; Reno, Sparks, and Carson City, Nevada; Bellevue, Redmond, and Issaquah, Washington; Boise, Meridian, and Eagle, Idaho; and Phoenix and Scottsdale, Arizona. The FTB has prioritized residency-audit examination of these departures under Cal. Rev. & Tax. Code §17014, the closer-connection nine-factor test, and the underlying authorities at Appeal of Stephen Bragg (2003-SBE-002), Appeal of Bindley (OTA 2018-OTA-179P), and Corbett v. FTB. The taxpayer who took a Texas, Washington, or Nevada W-2 in 2022 but kept the Cuesta Park, Whisman, Rex Manor, Sylvan Park, or Old Mountain View primary residence, the kids in the Mountain View Whisman School District, the cars on California plates, and the doctors at El Camino Health Mountain View or the Palo Alto Medical Foundation is the textbook FTB residency-audit profile, and the look-back routinely reaches three or four years.
Your tax rights as a Mountain View, California 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 Mountain View 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 closest IRS Taxpayer Assistance Center to Mountain View is the San Jose TAC on the 4th Floor at 55 S. Market Street, roughly ten miles southeast of the Googleplex. Most resolution work runs through the IRS Practitioner Priority Service, secure messaging, and direct contact with the assigned Revenue Officer or Settlement Officer.
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, FTB notices route to counsel — particularly useful in residency-audit examinations on the Austin-Reno-Bellevue-Boise Google-and-Intuit-departure pattern, where the FTB analyst working the matter sits in Sacramento and the taxpayer no longer wants the FTB certified-mail notices arriving at the Cuesta Park or Whisman home for spouse, parents, and college-age children to see.
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. A wage garnishment on a Google, Intuit, Microsoft, or LinkedIn paycheck stops on a properly filed Form 12153; so does a bank levy on a Wells Fargo, Chase, Citibank, Bank of America, or East West Bank account at any of the Castro Street, El Camino Real, San Antonio Road, or Shoreline Boulevard branches. Note that Alphabet processes withholding and W-2 reporting through a single centralized payroll function, which routes wage levies through one response queue — resolution timing matters.
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. Mountain View cases are heard at OTA Sacramento at 400 R Street, the OTA Los Angeles hearing room when scheduled, or by remote video appearance — OTA has standardized remote hearings since 2020, and most South Bay and mid-Peninsula residency-audit appeals proceed remotely.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Mountain View petitioners can designate San Francisco (Phillip Burton Federal Building, 450 Golden Gate Avenue) or San Jose (Robert F. Peckham Federal Building, 280 S. 1st Street) as the place of trial. The U.S. Tax Court holds regular sessions in San Francisco and periodic sessions in San Jose. The choice of trial city is made on the petition.
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). A Google engineer who exercised pre-IPO ISOs in a peak-valuation year at a since-acquired or since-collapsed Mountain View startup before joining Google and triggered a six- or seven-figure AMT liability, or an Indian-American family facing a multi-year FBAR and assessment problem on inherited Hyderabad or Chennai real estate, is a typical fact pattern.
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. The FTB compromise unit sits in Rancho Cordova; Mountain View engagements are handled by mail and secure messaging. California is generally tougher than the IRS on primary-residence equity — relevant for Mountain View households where a Cuesta Park, Old Mountain View, Waverly Park, or Sylvan Park primary residence often carries equity well above the IRS-allowed exclusion thresholds.
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. The longer California tail matters for the Austin-Reno-Bellevue-Boise-Phoenix departing-resident crowd: the move out of state does not erase the FTB’s reach over California-source income from Google GSU vests on grants made during California residency, ISO exercises during California residency, or pre-departure Schedule C consulting income.
How Victory Tax Lawyers helps Mountain View 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. Mountain View OIC files often turn on Google equity-comp cash-flow math: the engineer with vested-but-not-yet-sold Alphabet GSUs counted as W-2 income at vest under IRC §83(a), a pre-IPO AMT preference under IRC §56(b)(3) sitting in deferred AMT credit from a since-collapsed startup before the Google W-2 began, and a Reasonable Collection Potential analysis that has to account for the IRS Allowable Living Expense tables built for the San Francisco-Oakland-Hayward MSA. The Indian-American and Chinese-American small-business OIC files turn on Schedule C and foreign-disclosure reconstruction across the Castro Street, El Camino Real, San Antonio Road, and Showers Drive retail and restaurant operations. The post-departure OIC files for taxpayers now in Austin, Reno, Bellevue, Boise, or Phoenix turn on whether California-source-income tail liability can be addressed federally and at the FTB in parallel.
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 Mountain View households carrying Cuesta Park, Old Mountain View, Waverly Park, Sylvan Park, or Rex Manor mortgages with median home values well above $2 million, the disposable-income math depends heavily on which housing expenses the IRS will allow under the San Francisco-Oakland-Hayward MSA Allowable Living Expense table and which it will challenge as excessive. Long-held Mountain View parcels are Prop 13 protected with assessment baselines often well below market — useful in property-equity analysis — while recent purchases in North Bayshore, Whisman Station, and Castro Street infill projects carry near-market base-year values that compress the equity cushion.
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 Mountain View real and personal property and record at the Santa Clara County Recorder at 70 W. Hedding Street in San Jose. 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 Cuesta Park or Old Mountain View single-family, a Whisman townhouse, a Castro Street condo, or a Sylvan Park duplex can stall an escrow in a Mountain View housing market where multi-offer scenarios with short contingency periods are common.
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. A wage levy on a Google paycheck disrupts an equity-comp-heavy household in a particular way — the regular W-2 base for a Senior Software Engineer, Staff Software Engineer, or Principal Engineer at Google may be only 40 to 60 percent of total compensation, with the remainder coming through quarterly GSU vests, and a wage levy that hits during a vesting cycle can attach the entire GSU net. NASA Ames federal-civilian wage levies route through the Defense Finance and Accounting Service (DFAS) payroll function with a separate processing window.
Audit and exam defense
Federal correspondence, office, and field audits. FTB residency audits under Cal. Rev. & Tax. Code §17014 — the highest-volume FTB workload coming out of Mountain View since 2020, on Austin, Reno, Bellevue, Boise, and Phoenix Google, Intuit, Microsoft, and LinkedIn relocations. CDTFA sales-tax audits on the Castro Street, El Camino Real, San Antonio Center, and Showers Drive retail footprints. EDD AB 5 worker-classification audits on consulting, design, and software-contracting work done as 1099 instead of W-2. IRS examinations on IRC §1202 QSBS exclusions, IRC §83(b) elections, IRC §409A deferred-comp arrangements, IRC §1061 carried-interest classifications, and FBAR / Form 8938 disclosure adequacy on India, China, Taiwan, Korea, and Vietnam accounts.
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 Mountain View filers commonly include the 2020 SCU Lightning Complex evacuations and the smoke-impact closures across the broader Bay Area, recurring PG&E Public Safety Power Shutoff outages affecting the western foothills above Cuesta Park, serious illness with treatment at El Camino Health Mountain View or Stanford Hospital, and preparer reliance — particularly on Google equity-comp returns where the preparer mishandled GSU basis tracking or the pre-Google ISO AMT preference.
12 types of Mountain View tax issues we handle
Federal and California state practice areas, framed for the matters that walk in the door from the Googleplex, the Charleston East and Bay View campuses, the Intuit and Microsoft Silicon Valley campuses, NASA Ames at Moffett Federal Airfield, and the Castro Street, El Camino Real, and Whisman residential cores.
Google GSU vesting and supplemental under-withholding
Google Stock Units vest as W-2 ordinary income under IRC §83(a), with Alphabet withholding at the supplemental flat rate (22 percent under IRC §3402(a) up to $1 million per year and 37 percent above that). The flat 22 percent rate routinely under-withholds for a Google engineer in the 35 or 37 percent federal bracket, and the year-end true-up produces a balance-due return. Compound that with California’s 10.3 to 13.3 percent state rate under R&TC §17041 (and the 1 percent mental-health surtax over $1 million) and a typical GSU-heavy Google household can owe six figures at filing.
Pre-Google ISO exercises and the AMT trap
Incentive Stock Options qualify for capital-gains treatment on a sale that satisfies the IRC §422 holding periods (two years from grant and one year from exercise). The trap sits at exercise. The bargain element is not regular-tax income, but it is an Alternative Minimum Tax preference item under IRC §56(b)(3) reported on Form 6251. Pre-IPO exercises at a Mountain View startup before joining Google, with a low strike and a high 409A valuation, produce hundreds of dollars of AMT preference per share with no liquid stock to sell. The IRC §53 deferred AMT credit recovers the AMT over time, but the cash-flow problem in the exercise year is acute.
Intuit ESPP §423 disqualifying dispositions
Intuit operates a traditional IRC §423 Employee Stock Purchase Plan with a six-month offering period and a 15 percent lookback discount. A disqualifying disposition (selling within two years of grant or one year of purchase) recharacterizes the lookback discount as ordinary W-2 income on the disposition-year return, with the rest taxed as capital gain. The W-2 box 14 disclosure routinely confuses preparers, leading to double-reporting or missed-reporting of the ordinary-income adjustment. Intuit ESPP participants who sell within the disqualification window across multiple cycles accumulate prior-year reporting errors that surface as CP2000 notices two or three years later.
IRC §83(b) elections
A founder, early employee, or angel investor who receives restricted stock subject to vesting can elect within 30 days under IRC §83(b) to recognize the spread at grant rather than at vesting. The 30-day deadline is strict and the IRS cannot extend it. A missed §83(b) on a founder’s stock at a Google-alumni-founded Mountain View startup can cost millions of dollars in additional ordinary-income taxation at vest when the company has scaled up. The election is filed by mail to the IRS Service Center with a copy attached to the year-of-election return.
IRC §1202 QSBS planning and audit defense
Qualified Small Business Stock under IRC §1202 excludes up to the greater of $10 million or 10x basis on a sale after five years. The qualifying conditions are dense — original-issuance acquisition, $50 million gross-asset cap at issuance, active business under §1202(e), redemption traps under §1202(c)(3), the working-capital and real-estate limits — and any one failure disqualifies the entire position. California decoupled from §1202 in 2013 under R&TC §17152, so the exclusion is federal-only. Audit defense on QSBS exclusions for Google-alumni-founded companies and Mountain View startups acquired on strategic exits is a recurring large-dollar matter.
IRC §409A deferred compensation
Stock options issued below fair market value at grant, deferred-bonus arrangements, and supplemental executive retirement plans that miss the IRC §409A election and distribution rules trigger immediate income inclusion plus a 20 percent additional tax under §409A(a)(1)(B) plus interest. The 409A valuation requirement for private-company option grants is a recurring issue for Google engineers who hold pre-IPO option positions at startups they advise or have left behind — an option granted at a strike below the most recent 409A valuation is automatically nonqualified for §409A purposes and exposes the grantee to the 20 percent additional tax at vest.
IRC §1061 carried interest
The carried-interest rules under IRC §1061 extend the long-term-capital-gain holding period from one year to three years for partnership interests held in connection with services. The Sand Hill Road venture-capital ecosystem — with many GPs holding carried interest while living in Mountain View, Los Altos, and the broader mid-Peninsula — faces §1061 recharacterization on partnership distributions and exits, with the resulting reclassification from long-term capital gain (20 percent federal plus 3.8 percent NIIT) to short-term capital gain or ordinary income (up to 37 percent federal plus 13.3 percent California) producing a material tax-rate swing.
FBAR & Form 8938 disclosure
U.S. taxpayers with foreign financial accounts aggregating more than $10,000 at any point during the year file FinCEN Form 114 (FBAR) under 31 USC §5314. The Form 8938 (FATCA) filing threshold under IRC §6038D begins at $50,000 for single filers ($100,000 for joint) on year-end account balances. The Mountain View Indian-American H-1B and L-1 workforce in Whisman, Slater, and along El Camino Real carries NRE/NRO rupee accounts, demat brokerage, PPF/EPF retirement accounts, family-business retained earnings, and inherited property income on Bangalore, Mumbai, Hyderabad, Chennai, and Delhi parcels. The Chinese-American, Taiwanese-American, Korean-American, and Vietnamese-American communities carry parallel exposure on China, Hong Kong, Taiwan, Korea, and Vietnam accounts — all aggregating to reportable thresholds.
Streamlined Filing Compliance Procedure
The IRS Streamlined Filing Compliance Procedure (SFCP) — Domestic and Foreign streams — addresses non-willful past noncompliance on foreign-account disclosure. Streamlined Domestic requires three years of amended returns, six years of FBARs, a Form 14654 non-willful certification, and a 5 percent miscellaneous offshore penalty on the highest year-end account balance. Streamlined Foreign waives the penalty for taxpayers who meet the non-residency test. SFCP is the most common resolution path for Mountain View H-1B and L-1 visa-holder taxpayers who discover the FBAR obligation only after several years of U.S. residence, and for green-card holders who maintained substantial India, China, Taiwan, or Korea accounts before naturalizing.
FTB residency disputes (post-2020 departures)
The closer-connection test under Cal. Rev. & Tax. Code §17014 and FTB Pub. 1031 is the post-2020 Mountain View tax-controversy specialty. A Google, Intuit, Microsoft, or LinkedIn engineer who took a Texas, Nevada, Washington, Idaho, or Arizona W-2 in 2021 or 2022 while keeping the Cuesta Park, Whisman, or Old Mountain View primary residence, the kids in the Mountain View Whisman School District, the cars on California plates, the doctors at El Camino Health Mountain View, and the temple/church/mosque/gurdwara membership faces a multi-year FTB examination. The Appeal of Stephen Bragg nine-factor analysis controls; documentation of the move at the time of the move is what wins the appeal.
NASA Ames federal-civilian matters
NASA Ames Research Center civilian employees at Moffett Federal Airfield file under Title 5 of the U.S. Code with FERS basic annuity, Social Security, and Thrift Savings Plan coordination. TSP elective deferrals follow IRC §402(g), with separate catch-up rules. Intergovernmental Personnel Act details bring university and private-sector researchers onto NASA payroll temporarily with dual-status filing complications. Separation from federal service before age 55 triggers the IRC §72(t) 10 percent additional tax on early TSP withdrawals. Security clearance documentation affects Schedule C side-practice analysis and IRC §174 R&E expenditure capitalization.
Santa Clara County property tax & AAB
Prop 13 base-year value, Prop 8 decline-in-value applications, and Prop 19 parent-to-child exclusions all route through the Santa Clara County Assessor at 70 W. Hedding Street in San Jose. Assessment appeals go to the Santa Clara County Assessment Appeals Board at the same address under R&TC §1603-1611, with a 60-day filing window from the Annual Notice of Assessment or by September 15 for the regular roll. Prop 19 (effective 2021) limits the parent-to-child exclusion to a primary residence and the first $1 million of base-year value — a major change for multi-property Mountain View families that previously transferred rental and investment property at the parents’ base year. Long-held Old Mountain View, Cuesta Park, and Sylvan Park parcels often sit at base-year values far below current market, while recent purchases in North Bayshore and Whisman Station reset close to peak.
Nine common causes of tax debt in Mountain View
1. Google GSU supplemental under-withholding
A Google Senior Engineer, Staff Engineer, Principal Engineer, or Director receives GSU vests withheld at the IRC §3402(a) supplemental flat rate of 22 percent. The actual federal marginal rate is 35 or 37 percent. California withholding similarly under-shoots the actual 10.3 to 13.3 percent marginal rate. The year-end true-up produces a five- or six-figure balance due with failure-to-pay penalty and interest from April 15. This is the single most common cause of tax debt out of the Alphabet-anchored Mountain View workforce.
2. Pre-Google ISO exercise AMT
An engineer who exercised ISOs at a private Mountain View startup in a peak-409A-valuation year before joining Google, expecting capital-gains treatment on a future sale. The bargain element on exercise is an AMT preference item under IRC §56(b)(3). The startup misses or pushes its exit. The engineer cannot sell. The April 15 AMT bill arrives anyway, often after the Google W-2 has begun and the household is now a high-income Mountain View filer. Six- and seven-figure pre-Google AMT liabilities from this fact pattern are a recurring 2026 caseload.
3. Post-departure FTB residency audit
A Mountain View Google, Intuit, Microsoft, or LinkedIn worker accepts a Texas, Nevada, Washington, Idaho, or Arizona W-2 in 2021 or 2022 and files a part-year California return. The FTB pulls the file under §17014 and the Bragg nine-factor analysis — primary home location, vehicle registration, voter registration, driver’s license, family ties, medical and dental care, professional and social affiliations, location of spouse and dependents — and asserts continued California residency. Three or four prior years routinely come into the assessment.
4. FBAR / Form 8938 non-disclosure
An Indian-American, Chinese-American, Taiwanese-American, or Korean-American H-1B holder in Mountain View maintains family bank accounts, NRE/NRO accounts, demat brokerage, KOSPI-listed securities, or family-business retained earnings overseas aggregating well past the $10,000 FBAR threshold and the $50,000 Form 8938 threshold. The taxpayer first learns of the obligation at year five or six. The civil non-willful FBAR penalty is up to $10,000 per account per year, and the IRS asserts a Streamlined certification or full Offshore Voluntary Disclosure depending on the willfulness analysis.
5. Intuit ESPP §423 disposition error
An Intuit ESPP participant sells shares within the two-year-from-grant and one-year-from-purchase qualifying holding periods, triggering a disqualifying disposition under IRC §423. The lookback discount (15 percent off the lower of grant-date or purchase-date FMV) recharacterizes as W-2 ordinary income on the disposition-year return. The preparer either double-reports the discount (once on W-2 box 14 and again on Schedule D basis) or misses the ordinary-income adjustment entirely. CP2000 notices arrive two to three years later assessing tax, penalty, and interest on the misreported disposition.
6. QSBS qualification failure
A Mountain View founder or early employee sells C-corporation stock at a Google-alumni-founded startup after the five-year hold, claiming the IRC §1202 exclusion on $5 to $40 million of gain. The IRS examines the qualifying conditions — original-issuance acquisition, $50 million gross-asset cap at issuance, the active-business test, the redemption rules at §1202(c)(3), the working-capital limits — and disallows the exclusion on any one failure. The recharacterized gain hits federal long-term capital gain (20 percent plus 3.8 percent NIIT) plus California top rate (13.3 percent), erasing millions in expected exclusion benefit.
7. EDD AB 5 reclassification
A Mountain View software-consulting, design, or technical-writing professional treats five or six Bay Area clients as 1099 contracts. EDD applies the Dynamex ABC test codified at Cal. Lab. Code §2775 and reclassifies the contracts as W-2 employment. The hiring entities face back UI, ETT, SDI, and PIT withholding for three years plus penalties under Cal. Unemp. Ins. Code §1735. The contractor faces parallel reclassification on the federal side under IRS Form SS-8 analysis.
8. Missed §83(b) election
A founder at a Google-alumni-founded Mountain View startup receives restricted stock subject to a four-year vesting schedule. The 30-day §83(b) election window passes without filing. The stock vests over four years at increasing 409A valuations. Each tranche of vesting is ordinary income at the then-current FMV under IRC §83(a). On a company that grows from $1 per share at grant to $200 per share by final vest, the missed election can cost the founder millions in additional ordinary-income tax that a timely §83(b) would have eliminated.
9. Trust Fund Recovery Penalty
A Castro Street restaurant owner, an El Camino Real retailer, a Showers Drive small business, or a San Antonio Center merchant falls behind on Form 941 deposits during a slow season. The IRS asserts TFRP against the owner personally under IRC §6672 after a Form 4180 interview, and EDD assesses parallel state payroll liability under Cal. Unemp. Ins. Code §1735. The same exposure hits professional offices along Villa Street and Castro Street, Indian-American grocery and restaurant operators, and Chinese-American salon and retail operators across the Mountain View commercial footprint.
Who is on the hook: eight Mountain View 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. Common in Mountain View households where one spouse holds a Google W-2 with significant GSU exposure while the other operates a Schedule C consulting practice or family business along Castro Street or El Camino Real, and a Schedule C, GSU, or foreign-account lapse rolls onto the joint return.
Partnership and LLC general partners
Under IRC §6231 and the BBA centralized partnership audit regime, general partners and managing members of Sand Hill Road and mid-Peninsula venture funds, Mountain View family-LLC real-estate holding entities, multi-property holding LLCs, and Google-alumni-founder startup LLCs 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 Castro Street restaurant owners, El Camino Real retail operators, Showers Drive small-business principals, San Antonio Center merchants, Villa Street professional offices, and Indian-American and Chinese-American grocery and restaurant operators across the Mountain View retail footprint. The IRS Form 4180 interview is the gateway to TFRP assessment.
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 Castro Street restaurants and retail, El Camino Real merchants, Showers Drive retail, San Antonio Center operators, and Villa Street service businesses after the business closes. The CDTFA San Jose office at 250 S. 2nd Street is where these audits originate for Mountain View businesses.
FTB suspended-entity personal exposure
An entity that fails to pay the 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 Santa Clara County Superior Court at 191 N. 1st Street in San Jose. Officers signing on behalf during suspension can incur personal exposure, and FTB assesses the $800 minimum franchise tax for each tax year of suspension.
Transferee liability
IRC §6901 reaches a transferee of assets where the transfer rendered the transferor insolvent and tax debts remain unpaid. Mountain View family-LLC restructurings, Prop 19 parent-to-child transfers under Cal. Const. Art. XIII A on Cuesta Park, Old Mountain View, Sylvan Park, and Waverly Park primary residences, and inter-family transfers of Indian-American or Chinese-American family-business assets along Castro Street can all trigger this analysis. The FTB has parallel transferee authority under Cal. Rev. & Tax. Code §19071.
Successor business liability
Asset purchases of a Castro Street restaurant, an El Camino Real retail unit, a Showers Drive merchant, a San Antonio Center operator, or a Villa Street professional office 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.
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 Mountain View estates — including the Cuesta Park, Old Mountain View, and Sylvan Park primary residences, Alphabet GSU unsold positions with substantial IRC §1014 step-up at death, Intuit ESPP shares from multiple offering cycles, and inherited India, China, Taiwan, or Korea real-estate interests — moves through the Santa Clara County Superior Court Probate Division at the Downtown Superior Courthouse on N. 1st Street in San Jose.
What resolution can look like in Mountain View
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 FTB compromise unit handles Mountain View files out of 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 — particularly useful for the engineer who exercised pre-Google ISOs into a six-figure AMT and is waiting for a liquidity event that may or may not arrive.
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 the 2020 SCU Lightning Complex evacuations and smoke-impact closures across the broader Bay Area, the recurring PG&E Public Safety Power Shutoff outages affecting the western foothills above Cuesta Park, serious illness with treatment at El Camino Health Mountain View, Stanford Hospital, or the Palo Alto Medical Foundation, and Google equity-comp preparer error. 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 Mountain View real property in a market where buyers waive contingencies on three- to five-day timelines. 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 — relevant for the H-1B and L-1 community traveling back to India, China, Taiwan, Korea, and Vietnam, and for green-card holders traveling for family or business reasons.
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. Past results do not guarantee future outcomes — each case is unique and depends on facts, asset position, and IRS or FTB discretion.
| 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 Mountain View tax matter
Mountain View taxpayers deal with two tax systems that interact in ways most out-of-state firms do not understand — and additional layers arrive when the Google equity-compensation complex, the pre-Google startup ISO AMT trap, the Intuit ESPP §423 disqualifying-disposition pattern, the IRC §1202 QSBS pipeline from Google-alumni-founded startups, the FBAR and Form 8938 exposure across the Indian-American, Chinese-American, Taiwanese-American, and Korean-American community, the NASA Ames federal-civilian Title 5 / FERS / TSP filings, the U.S.-India and U.S.-China tax-treaty coordination, and the post-2020 Mountain-View-to-Austin Google-departing-resident audit caseload all sit on top of one another in the same household. A Google Staff Engineer with vested Alphabet GSUs, a pre-Google startup ISO position still untaxed for AMT purposes, an Indian parent’s NRE rupee account, a Cuesta Park primary residence, and a 2022 transfer to Austin can have GSU under-withholding exposure on one tax year, AMT exposure on another, FBAR exposure across multiple years, and an FTB residency-audit exposure on a fifth. A federal NFTL filed with the Santa Clara County Recorder at 70 W. Hedding Street sits in the same recording index as the FTB’s own State Tax Lien on the same Cuesta Park 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 on the California side. The same attorneys handle the whole engagement from initial Form 12153 through final Tax Court trial in San Francisco or San Jose.
California is one of the most lawyer-intensive tax environments in the country. The State Bar’s Rule of Professional Conduct 7.1 tightly governs lawyer advertising — 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.
Mountain View engagements are handled remotely via Form 2848 federal authority and FTB Form 3520-PIT California authority, or in person for hearings at the Robert F. Peckham Federal Building at 280 S. 1st Street in San Jose (about ten miles southeast), the Santa Clara County Superior Court at 191 N. 1st Street, the FTB San Jose Field Office at 96 N. 3rd Street, the CDTFA San Jose office at 250 S. 2nd Street, the IRS Taxpayer Assistance Center at 55 S. Market Street 4th Floor, and the Santa Clara County Assessor and Assessment Appeals Board at 70 W. Hedding Street, East Wing, 5th Floor.
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 Mountain View 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 — a tolling factor that hits Mountain View H-1B holders who return to India, China, Taiwan, Korea, or Vietnam for extended family-care leave.
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 Mountain View 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 Google engineers, Intuit product managers, Microsoft researchers, and LinkedIn executives who have since relocated — whether to Austin, Reno, Bellevue, Boise, Phoenix, or back to India under an L-1 reverse-rotation — the FTB tail still attaches to California-source income earned during the years of California residency. Alphabet GSU income from grants made during California residency remains California-source under R&TC §17041 and the FTB sourcing rules at FTB Pub. 1004, even when the vesting occurs after the move. ISO exercises during California residency remain California-source. Intuit ESPP disqualifying-disposition ordinary income on shares purchased during California residency remains California-source. The move forward does not erase the look-back. The Mental Health Services Act 1 percent surtax on income above $1 million under Cal. Rev. & Tax. Code §17043 applies the same way during the residency years, and a one-time large GSU-cliff vest or QSBS sale can trigger the surtax even in a year the taxpayer thinks of as part-year.
Mountain View venue: where federal and state tax matters are heard
Mountain View itself does not house a federal courthouse, IRS Taxpayer Assistance Center, FTB field office, CDTFA office, or county-level tax facility. The complete federal and state tax-controversy footprint serving Mountain View sits in downtown San Jose (about ten miles southeast of the Googleplex) for federal court matters and county property-tax appeals, with FTB and CDTFA offices in San Jose, and U.S. Tax Court sessions split between San Francisco and San Jose. The City of Mountain View itself operates its City Hall at 500 Castro Street, 94041, with the City’s Business License office handling local business-tax registration under Mountain View Municipal Code Chapter 18 (the local business-tax certificate program), and the Mountain View Rental Housing Committee at 555 Castro Street handling CSFRA petitions. State appellate matters from Mountain View go to the California Court of Appeal, Sixth Appellate District, at 333 W. Santa Clara Street in San Jose. The federal appellate court for tax-litigation appeals is the U.S. Court of Appeals for the Ninth Circuit in San Francisco.
U.S. Tax Court — San Francisco and San Jose
The U.S. Tax Court designates San Francisco (Phillip Burton Federal Building, 450 Golden Gate Avenue, San Francisco 94102) as a regular place of trial, with periodic San Jose sessions held at the Robert F. Peckham Federal Building, 280 S. 1st Street, San Jose 95113. Mountain View petitioners typically designate San Francisco for the wider session calendar, with San Jose available for specific dates — San Jose is closer but San Francisco has a much wider session schedule. The federal U.S. Tax Court bar admission is national; the firm appears at both locations.
IRS Taxpayer Assistance Center — San Jose
The IRS San Jose Taxpayer Assistance Center is located at 55 S. Market Street, 4th Floor, San Jose 95113 — the closest IRS TAC to Mountain View, about ten miles southeast of the Googleplex. Appointments are required and arranged through apps.irs.gov/app/office-locator or 844-545-5640. The TAC handles in-person Identity Verification, Individual Taxpayer Identification Number (ITIN) applications, payment receipts, and limited account inquiries.
Robert F. Peckham Federal Building
The Robert F. Peckham Federal Building and U.S. Courthouse at 280 S. 1st Street, San Jose 95113 houses the U.S. District Court for the Northern District of California San Jose Division, the U.S. Bankruptcy Court San Jose Division (which handles bankruptcy proceedings with tax-claim components), and federal agency offices. Refund actions under 26 USC §7422, federal tax-injunction matters, and criminal-tax cases originating in Mountain View and the broader Santa Clara County file here. Appeals go to the U.S. Court of Appeals for the Ninth Circuit in San Francisco.
FTB San Jose Field Office
The FTB San Jose Field Office is located at 96 N. 3rd Street, San Jose 95112. FTB field offices handle in-person taxpayer assistance, residency-audit and other field-examination meetings, and FTB collection conferences. The FTB compromise unit, the FTB residency-audit unit, and the FTB Settlement Bureau all sit at FTB headquarters in Rancho Cordova; the San Jose field office is the regional point for direct meetings with examiners assigned to Mountain View and the broader mid-Peninsula residency-audit pipeline.
CDTFA San Jose Office
The CDTFA San Jose office is located at 250 S. 2nd Street, San Jose 95113. CDTFA San Jose handles sales-and-use tax audits for Mountain View and Santa Clara County businesses, including the Castro Street, El Camino Real, San Antonio Center, Showers Drive, and Villa Street retail and restaurant footprint. Sales-tax determinations issued out of this office route to OTA on appeal.
Santa Clara County Assessor & AAB
The Santa Clara County Assessor at 70 W. Hedding Street, East Wing, 5th Floor, San Jose 95110, sets Prop 13 base-year value and annual assessed value for every parcel in Mountain View. The Santa Clara County Assessment Appeals Board sits at the same address and hears appeals under R&TC §1603-1611 with a 60-day filing window from the Annual Notice of Assessment or by September 15 for the regular roll. Prop 19 parent-to-child reassessment exclusions, Prop 8 decline-in-value applications, and Mountain View CFD or special-district assessment questions all start here.
Santa Clara County Treasurer-Tax Collector
The Santa Clara County Treasurer-Tax Collector at 70 W. Hedding Street, East Wing, 6th Floor, San Jose 95110 collects secured-roll property taxes on Mountain View parcels under R&TC §2607-2611, with delinquency, penalty, and tax-default sale procedures governed by R&TC §3691 et seq. The 5-year redemption window before tax-defaulted property goes to public auction matters in distressed Mountain View matters.
Court of Appeal, Sixth Appellate District
The California Court of Appeal, Sixth Appellate District, sits at 333 W. Santa Clara Street, Suite 1060, San Jose 95113. The Sixth District has territorial jurisdiction over Santa Clara, San Benito, Monterey, and Santa Cruz counties and hears appeals from Santa Clara County Superior Court tax-refund actions under R&TC §19382 and §19385, FTB and CDTFA collection-litigation appeals, and judicial review of OTA decisions. The published opinions of the Sixth District control on tax matters arising in Mountain View until and unless the California Supreme Court accepts review.
City of Mountain View — business license & CSFRA
Mountain View City Hall at 500 Castro Street, 94041 administers the city Business License Tax under the Mountain View Municipal Code and the Community Stabilization and Fair Rent Act (CSFRA, Article XVII of the City Charter, adopted 2016) through the Rental Housing Committee at 555 Castro Street. CSFRA caps annual rent increases on covered multi-family rental units at a CPI-based formula and operates a petition process for upward adjustments. Schedule E Mountain View rental matters routinely intersect with CSFRA petition records and Prop 8 decline-in-value analyses at the County Assessor.
Santa Clara County Superior Court
The Santa Clara County Superior Court Downtown facility at 191 N. 1st Street, San Jose 95113 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. The court website at scscourt.org publishes calendars and filing requirements.
VTL represents clients across Mountain View city limits including the Googleplex and the North Bayshore campus footprint (Charleston East, the Bay View campus, Shoreline Boulevard and Charleston Road buildings), Intuit headquarters at 2700 Coast Avenue, Microsoft Silicon Valley at 1065 La Avenida, NASA Ames Research Center at Moffett Federal Airfield, the Castro Street downtown corridor, the El Camino Real and Showers Drive commercial spines, the San Antonio Center retail district, El Camino Health Mountain View, and the Old Mountain View, Cuesta Park, Rex Manor, Sylvan Park, Whisman, Monta Loma, Waverly Park, North Whisman, Slater, and Willowgate residential neighborhoods. Across the city limits we also represent neighboring communities including Palo Alto and Los Altos to the northwest, Sunnyvale to the east, Cupertino to the southeast, and Los Altos Hills to the south.
Request a free consultation with a Mountain View 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 equity-comp paperwork (Google GSU grant and vesting schedules from Morgan Stanley or Charles Schwab, Intuit ESPP offering and purchase statements with the IRC §423 lookback discount details, Microsoft and LinkedIn equity statements, ISO grant and exercise records from any pre-Google startup, IRC §83(b) election copies for pre-Google founder stock, IRC §1202 QSBS qualification documentation, IRC §409A valuations), any foreign-account statements if you carry FBAR or Form 8938 exposure (NRE/NRO statements, demat brokerage, PPF/EPF, China, Hong Kong, Taiwan, Korea, Vietnam accounts), any move-related documentation if you departed for Texas, Nevada, Washington, Idaho, or Arizona after 2020 (lease, deed, new-state W-2, vehicle registration, driver’s license, voter registration), any NASA Ames FERS/TSP statements if applicable, any FTB, CDTFA, EDD, or Santa Clara County Assessor correspondence, and any Santa Clara County Treasurer-Tax Collector property-tax bills. 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 Mountain View and the entire mid-Peninsula by phone, secure portal, and in person at the Robert F. Peckham Federal Building when an in-person hearing is required.
Frequently asked questions for Mountain View taxpayers
Author and editorial attestation
Written 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 on the post-2020 Austin, Reno, Bellevue, Boise, and Phoenix Mountain-View-employee-departing-resident pattern, Google-anchored Mountain View equity-compensation matters (GSU vesting and supplemental-withholding gaps, pre-Google ISO Alternative Minimum Tax exposure on pre-Google pre-IPO startup exercises, Intuit ESPP IRC §423 lookback-discount and qualifying-versus-disqualifying-disposition analysis, IRC §83(b) election protection on pre-Google founder grants, IRC §1202 Qualified Small Business Stock exclusion qualification and audit defense on Google-alumni-founder positions, IRC §409A deferred-compensation analysis, IRC §1061 carried-interest classification), FBAR and Form 8938 disclosure and Streamlined Filing Compliance Procedure submissions for the Mountain View Indian-American, Chinese-American, Taiwanese-American, Korean-American, and Vietnamese-American H-1B and L-1 visa-holder community, U.S.-India and U.S.-China tax-treaty coordination, Santa Clara County property-tax assessment appeals on Old Mountain View, Cuesta Park, Sylvan Park, Waverly Park, and Whisman primary residences, CDTFA sales-tax representation on the Castro Street, El Camino Real, San Antonio Center, Showers Drive, and Villa Street retail footprint, NASA Ames federal-civilian Title 5 / FERS / TSP filings, CSFRA-affected Schedule E rental matters, EDD AB 5 worker-classification audits, OTA appeals, and litigation before the U.S. Tax Court San Francisco and San Jose sessions and the U.S. District Court for the Northern District of California San Jose Division at the Robert F. Peckham Federal Building.
Reviewed by
Amir Boroumand, Esq.
Managing Attorney · California Bar #269570 · Admitted to the United States Tax Court
Amir Boroumand serves as the editorial reviewer for this page. As a managing attorney of Victory Tax Lawyers, LLP and a member of the State Bar of California in active standing, Amir reviewed the content for accuracy on California tax law (R&TC, UIC, Cal. Gov. Code, Cal. Fam. Code), federal Internal Revenue Code citations, U.S. Tax Court jurisdiction and venue, FTB closer-connection residency-audit law (Bragg, Bindley, Corbett), Santa Clara County assessment-appeal procedure under R&TC §1603-1611, and Mountain View Municipal Code citations including the Community Stabilization and Fair Rent Act (CSFRA). The two-attorney write-and-review workflow is standard practice on every Victory Tax Lawyers California-city resource page.
Last Reviewed: . Both attorneys are members of the State Bar of California in active standing and are admitted to practice before the United States Tax Court. California Bar verification: Parham Khorsandi #266658 · Amir Boroumand #269570.
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 Santa Clara County Treasurer-Tax Collector, the Santa Clara 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), Santa Clara County property-tax matters, and federal IRS, U.S. Tax Court, and U.S. District Court Northern District of California San Jose Division 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.
Related VTL practice areas
Offer in Compromise
IRC §7122 settlement
Installment Agreement
IRC §6159 payment plan
Tax Lien
IRC §6321 release
Tax Levy
IRC §6331 release
Audit Representation
IRS exam defense
Penalty Abatement
First-Time and reasonable cause
Back Taxes
Unfiled returns and balances
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