I would like to take a moment to express my sincere appreciation for the excellent service and representation I received from my lawyer Parkam. Throughout the entire process, he was extremely professional, efficient, and successful in handling my case. Every time I called, he was always responsive, answered my questions promptly, and made sure everything was handled exactly the way I wanted. His dedication, communication, and attention to detail gave me great confidence and peace of mind. I truly appreciate all the hard work and effort that was put into achieving the best possible outcome. I highly recommend his services to anyone looking for a trustworthy, knowledgeable, and results-driven attorney. Thank you again for the outstanding support and professionalism.
Tax Attorney in Pleasanton, California
What this page covers
- Federal IRS, U.S. Tax Court, and California FTB / CDTFA / EDD representation for Pleasanton taxpayers
- Workday (6110 Stoneridge Mall Rd), Veeva Systems, Roche Diagnostics (4300 Hacienda Dr), and ICE Mortgage Technology RSU and ISO §83(b) / AMT / §1202 QSBS planning
- FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing for Indian-American (ICICI, HDFC, SBI) and Chinese-American (Bank of China, ICBC, CCB) accounts
- IRC §174 R&E capitalization and §41 research credit interaction for Hacienda Business Park life-sciences and SaaS employees
- Mello-Roos CFD review for Ruby Hill, Vintage Hills, and Bridle Creek parcels; Prop 8 decline-in-value appeals at the Alameda County AAB (1221 Oak Street, Sept. 15 deadline)
- Tri-Valley BART commute §132 transit fringe; Livermore Valley AVA wine-adjacent Schedule C work; Alameda County Fair / Pleasanton Race Track 1099 income
Federal IRS and California state tax representation for Pleasanton taxpayers — from the Workday headquarters campus at 6110 Stoneridge Mall Road, the Veeva Systems life-sciences SaaS workforce on Owens Drive, the Roche Diagnostics pharma campus at 4300 Hacienda Drive, the ICE Mortgage Technology (formerly Ellie Mae) team, the broader Hacienda Business Park (largest commercial business park west of the Mississippi at build-out), the Stoneridge Shopping Center retail anchor, the Indian-American and Chinese-American community concentration with cross-border account exposure at ICICI / HDFC / State Bank of India / Bank of China / ICBC / CCB, the Ruby Hill / Vintage Hills / Castlewood / Foothill / Val Vista residential corridors, the Alameda County Fairgrounds at 4501 Pleasanton Avenue, Pleasanton Unified teacher CalSTRS households, and the Tri-Valley BART commute corridor to San Francisco and the Peninsula. Our California Bar-admitted attorneys appear at the IRS Oakland Taxpayer Assistance Center at 1301 Clay Street in the Ronald V. Dellums Federal Building, the FTB Oakland Field Office at 1515 Clay Street in the Elihu M. Harris State Office Building, the CDTFA Oakland District Office, the Alameda County Assessment Appeals Board at 1221 Oak Street, and U.S. Tax Court trial sessions at the Phillip Burton Federal Building, 450 Golden Gate Avenue, San Francisco.
By Amir Boroumand, Esq. — California Bar #269570. Admitted to practice before the United States Tax Court. Last Reviewed: .
Request a Free Consultation
100% Free · Confidential · No Obligation
Cal Bar Admitted
Verifiable license #269570
U.S. Tax Court
San Francisco trial sessions
Tri-Valley Tech & FBAR
Workday, Veeva, Roche, ICICI / HDFC / BOC
5.0 / 72 Reviews
Google Business Profile
Pleasanton taxpayers facing IRS collection, FTB assessment, CDTFA audit, FBAR exposure, or county AAB reassessment
If you live or work in Pleasanton — the Workday corporate headquarters at 6110 Stoneridge Mall Road, the Veeva Systems life-sciences SaaS campus on Owens Drive, the Roche Diagnostics pharma operation at 4300 Hacienda Drive, the ICE Mortgage Technology team at 1 Ellie Mae Way, the broader Hacienda Business Park with over 600 companies across 10 million square feet of commercial space, the Stoneridge Shopping Center retail anchor with Macy's and Nordstrom, the Indian-American and Chinese-American residential communities concentrated across Ruby Hill, Vintage Hills, Castlewood, Foothill, Val Vista, and Mohr Park, the Pleasanton Unified School District teacher households running CalSTRS plus §403(b) plans, the Alameda County Fairgrounds and Pleasanton Race Track operation at 4501 Pleasanton Avenue, or the Tri-Valley BART commute corridor from Downtown Pleasanton Station (5709 Bernal Avenue) and Dublin/Pleasanton Station (5801 Owens Court) to San Francisco and the Peninsula — you sit on a Tri-Valley city of roughly 80,000 with one of the densest concentrations of enterprise-SaaS, pharma, and fintech employment in California. Each thread carries a different federal and California tax profile. This page walks through what Pleasanton representation looks like in practice.
$100M+
Total tax relief secured
2,000+
Tax cases resolved
5.0
Average rating · 72 reviews
CA-Based
Los Angeles home office
Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.
Why Pleasanton tax matters call for a California-licensed firm
Pleasanton is a Tri-Valley city in eastern Alameda County, roughly 80,000 residents across the Amador Valley between Dublin and Livermore, with ZIP codes 94566 (south and east) and 94588 (north and west). Connections to the broader Bay Area run I-580 west to Oakland and the East Bay, I-680 north to Walnut Creek and south to San Jose, and the Tri-Valley BART line from Downtown Pleasanton (5709 Bernal Avenue) and Dublin/Pleasanton Station (5801 Owens Court) to the Lake Merritt and Embarcadero transfer points and on to San Francisco and the Peninsula. The economy is built around five anchors. First, Workday, Inc. — the Fortune-500 enterprise human-capital and financial-management SaaS company — sits at 6110 Stoneridge Mall Road as its corporate headquarters with thousands of Pleasanton-based engineers, product managers, sales, and finance professionals. Second, Veeva Systems on Owens Drive — the life-sciences cloud-software company — anchors a comparable workforce focused on pharma and biotech CRM, regulatory, and quality systems. Third, Roche Diagnostics at 4300 Hacienda Drive operates a pharma research and diagnostics campus that ties into the Roche Holding global research footprint. Fourth, ICE Mortgage Technology (formerly Ellie Mae) at 1 Ellie Mae Way handles mortgage-origination software for a large fraction of the U.S. residential lending market. Fifth, the broader Hacienda Business Park — at build-out the largest commercial business park west of the Mississippi River, more than 870 acres and over 10 million square feet of office, R&D, and flex space — houses Kaiser Permanente Pleasanton (4555 Hopyard Road), Polycom, Albertsons / Safeway corporate operations historically, and several hundred smaller employers. The residential corridor — Ruby Hill, Vintage Hills, Castlewood, Foothill, Val Vista, Mohr Park, downtown Pleasanton along Main Street, Vineyard Avenue, and Sycamore Park — houses senior tech, pharma, and finance professionals plus Pleasanton Unified School District teacher households.
Victory Tax Lawyers, LLP is a California-licensed tax-law firm. Both managing attorneys — Parham Khorsandi, Cal Bar #266658, and Amir Boroumand, Cal Bar #269570 — are members of the State Bar of California in active standing and admitted to practice before the United States Tax Court. We represent Pleasanton clients directly before the California Franchise Tax Board, CDTFA, EDD, and the California Office of Tax Appeals — no Power-of-Attorney workaround through out-of-state counsel, no referral chain.
On the federal side, U.S. Tax Court bar admission has nationwide reach. A Pleasanton petitioner typically designates San Francisco as the place of trial under Tax Court Rule 140, with sessions held at the Phillip Burton Federal Building, 450 Golden Gate Avenue. The IRS Oakland Taxpayer Assistance Center at 1301 Clay Street in the Ronald V. Dellums Federal Building, the FTB Oakland Field Office at 1515 Clay Street in the Elihu M. Harris State Office Building, and the CDTFA Oakland District Office handle the day-to-day administrative work for Pleasanton residents. Pleasanton's federal docket runs through the U.S. District Court for the Northern District of California, Oakland Division at the Ronald V. Dellums Federal Building (1301 Clay Street). We appear at all of these venues.
The sections that follow set out the practice areas, the venue map, settlement ranges from prior cases, the seven-step engagement process, and 18 FAQs answering what Pleasanton taxpayers actually ask.
Your tax rights as a Pleasanton taxpayer
Federal taxpayer rights sit in the Internal Revenue Code and IRS Publication 1. California layers its own protections through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel rights inside CDTFA and EDD. Pleasanton property owners add Prop 13 base-year, Prop 19 parent-child, and Prop 8 decline-in-value protections at the Alameda County Assessor.
Right to representation (federal)
Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview when you state you wish to consult an authorized representative. Form 2848 puts a tax attorney between you and the IRS for the rest of the matter — including the field RO who shows up at a Hacienda Business Park office, a Stoneridge-area retail operation, a downtown Pleasanton residence, or a Ruby Hill or Vintage Hills address.
Right to representation (California)
FTB Form 3520-PIT or 3520-BE appoints counsel before the Franchise Tax Board. CDTFA Form 392 covers sales-and-fuel-tax matters; EDD DE 48 covers payroll. Once on file, every notice routes to your attorney rather than your Pleasanton address on Ruby Hill, Vintage Hills, Castlewood, Foothill, or downtown.
Right to Collection Due Process
A Notice of Federal Tax Lien (IRC §6320) or Final Notice of Intent to Levy (IRC §6330) opens a 30-day window to request a CDP hearing on Form 12153. A timely CDP request pauses federal collection and preserves Tax Court review — important on Workday or Veeva payroll-account levies during quarterly close periods, ICE Mortgage Technology and Roche payroll levies, and residential bank-account levies on Ruby Hill, Vintage Hills, and Castlewood accounts.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Pleasanton petitioners commonly designate San Francisco as the place of trial, with sessions held at the Phillip Burton Federal Building at 450 Golden Gate Avenue. Sacramento is an alternative where docket timing favors it.
Right to an FTB protest and OTA appeal
A Notice of Proposed Assessment from the FTB carries a 60-day protest window under Cal. Rev. & Tax. Code §19041. The Notice of Action that follows opens a 30-day appeal to the California Office of Tax Appeals under §19045. The OTA hears the matter as an independent tribunal — no longer the State Board of Equalization — with hearing rooms in Sacramento (400 R Street headquarters) and Los Angeles (355 South Grand Avenue). Video appearance is the practical option for most Pleasanton matters.
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). The Reasonable Collection Potential math treats Ruby Hill golf-course home equity, Vintage Hills equity, Workday and Veeva RSU positions, Roche stock holdings, and W-2 income from Hacienda Business Park employers differently than the Inland Empire patterns the IRS sees from Riverside or San Bernardino.
Right to a California OIC
FTB compromise authority sits at Cal. Rev. & Tax. Code §19443. CDTFA runs a parallel offer program under §6832. EDD compromise sits at Cal. Unemp. Ins. Code §1735 and adjoining sections.
Right to a Collection Statute (federal 10 vs. California 20)
IRC §6502 gives the IRS 10 years from assessment to collect. The California parallel under Cal. Rev. & Tax. Code §19255 runs 20 years — double the federal tail. Pull both transcripts before negotiating any Pleasanton resolution.
How Victory Tax Lawyers helps Pleasanton taxpayers
Federal & California Offer in Compromise
We 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. The two reviews run on different Reasonable Collection Potential math. Ruby Hill golf-frontage equity, Vintage Hills home equity, Castlewood country-club property, Workday and Veeva W-2 plus RSU positions, Roche pharma compensation, ICE Mortgage Technology equity holdings, and ICICI / HDFC / Bank of China foreign-account positions all need correct valuation before either filing.
Installment Agreements (IRS & FTB)
Streamlined IRS IAs under $50,000, Non-Streamlined IAs above with Form 433-F disclosure, and Partial Pay IAs under IRC §6159 running through the CSED. FTB parallel plans under Form 3567; CDTFA and EDD have their own structures. Workday and Veeva employees carrying RSU vest underwithholding, Roche employees with ESPP §423 balance shocks, ICE Mortgage Technology equity-comp holders, and 1099 Hacienda Business Park contractors all need a structure that survives Tri-Valley income volatility.
Lien release and withdrawal
A federal NFTL under IRC §6321 and FTB State Tax Liens under Cal. Gov. Code §7170 attach to Pleasanton real property and record with the Alameda County Clerk-Recorder at 1106 Madison Street, Oakland. We pursue release after payment, certificate of discharge for sale or refinance, subordination on Ruby Hill and Vintage Hills refinances, and lien withdrawal under Fresh Start for IAs under $25,000.
Levy release (IRS, FTB, EDD)
Federal wage and bank levies under IRC §6331 stop with CNC, an accepted IA, OIC processing, or a timely CDP. FTB Earnings Withholding Orders under Cal. Rev. & Tax. Code §18670 and bank levies under §18670.5 release under analogous resolutions. Federal bank levies hold 21 days; FTB holds 10 business days — the shorter California window makes timing decisive on Workday and Veeva payroll accounts, Hacienda Business Park operating accounts at Mechanics Bank, Heritage Bank of Commerce, and First Republic, and 1099 receivables for Pleasanton contractors.
FBAR, Form 8938 & Streamlined Filing
For Pleasanton's Indian-American and Chinese-American community with cross-border accounts at ICICI, HDFC, State Bank of India, Bank of China, ICBC, China Construction Bank, and Hong Kong-based banks, we file FinCEN Form 114 (FBAR) under 31 USC §5314, Form 8938 under IRC §6038D, and Form 8621 PFIC where Indian mutual funds, ULIP policies, PPF, or Chinese mutual funds are held. The Streamlined Domestic Offshore Procedure (5 percent miscellaneous offshore penalty) and Streamlined Foreign Offshore Procedure (zero-penalty) cure non-willful exposure; the IRS Voluntary Disclosure Practice handles willful exposure. Penalty math under 31 USC §5321 reaches the greater of $100,000 or 50 percent of the account balance on willful non-filings.
Audit and exam defense
IRS correspondence, office, and field audits handled at the Oakland TAC at 1301 Clay Street. FTB residency audits under Cal. Rev. & Tax. Code §17014 on Pleasanton departures to Austin, Reno, Boise, and Coeur d'Alene. CDTFA sales-tax audits on Stoneridge Shopping Center anchor and inline retail, Hacienda Business Park flex-space tenants, and the downtown Main Street corridor handled out of the CDTFA Oakland District Office. EDD employment-tax audits on Hacienda Business Park contract workers and Tri-Valley independent contractors. FBAR examination defense coordinated separately under the IRS Large Business & International division.
Penalty abatement
Federal First-Time Penalty Abatement and reasonable-cause requests under IRC §6651. FTB waivers under Cal. Rev. & Tax. Code §19131 and §19132. Reasonable-cause for Pleasanton filers affected by 2020 wildfire smoke (SCU Lightning Complex air-quality closures), COVID-era Hacienda Business Park shutdowns, the 2018-2019 SF Bay Area PG&E PSPS events, and serious illness or family bereavement.
AAB & Prop 8 decline-in-value appeals
Pleasanton Prop 13 base-year values from 2020-2022 purchases often exceed the post-cooling market in Ruby Hill, Vintage Hills, Castlewood, Foothill, and Val Vista. We file the informal Decline in Market Value Reassessment with the Alameda County Assessor and the formal AAB application before the September 15 deadline at 1221 Oak Street, Oakland. Mello-Roos CFD line items on Ruby Hill, Vintage Hills, and Bridle Creek parcels are reviewed for procedural-defect challenges under Government Code §53341 in parallel.
Twelve tax issues we handle for Pleasanton clients
Federal and California state practice areas framed for matters that walk through the door from the Workday and Veeva enterprise-SaaS workforce, the Roche pharma campus, the ICE Mortgage Technology team, the broader Hacienda Business Park, the Indian-American and Chinese-American community, and the residential neighborhoods of Ruby Hill, Vintage Hills, Castlewood, Foothill, Val Vista, Mohr Park, and downtown Pleasanton.
Workday & Veeva RSU, ISO & AMT
Workday HQ at 6110 Stoneridge Mall Road, Veeva Systems on Owens Drive, ICE Mortgage Technology at 1 Ellie Mae Way, and the broader Hacienda Business Park run on RSU and stock-option compensation. RSU vests withhold at the flat 22 percent supplemental rate under IRC §3402(g), undershooting California's 13.3 percent top bracket combined with federal 37 percent. ISO exercises trigger the AMT preference under IRC §56(b)(3) on the spread between strike and FMV; pre-public exercises produce substantial AMT in the exercise year with the §53 minimum-tax credit recoverable later. We file Streamlined or Non-Streamlined IAs, reset withholding going forward, and run the AMT analysis before exercise where the structure is still flexible.
§1202 QSBS for early-stage Pleasanton founders
Founders, early employees, and seed investors in Pleasanton-based and Tri-Valley-based startups should run IRC §1202 Qualified Small Business Stock eligibility before any disposition. C-corp issuance, $50M gross-assets cap at issuance, qualified-trade-or-business test, and the five-year holding period each have to clear. The exclusion runs up to 100 percent of gain on post-September-2010 acquired stock, capped per issuer at the greater of $10M or ten-times-basis. California does not conform to §1202 post-2013 — the federal exclusion does not eliminate California tax on the gain. We coordinate the federal exclusion with the California sourcing analysis on departure from California before sale.
FBAR & Form 8938 (ICICI, HDFC, SBI)
Pleasanton's Indian-American community concentration drives a recurring FinCEN Form 114 FBAR and IRS Form 8938 compliance load on ICICI Bank, HDFC Bank, State Bank of India, Axis Bank, Kotak Mahindra, Public Provident Fund, and Employees' Provident Fund accounts. Threshold: aggregate foreign accounts over $10,000 at any point in the calendar year triggers FBAR under 31 USC §5314. Indian mutual funds and ULIP policies trigger Form 8621 PFIC reporting under IRC §1297. We file Streamlined Domestic Offshore (5 percent penalty) and Streamlined Foreign Offshore (zero penalty) where exposure is non-willful, and the IRS Voluntary Disclosure Practice for willful exposure.
FBAR (Bank of China, ICBC, CCB)
The Pleasanton Chinese-American community holds accounts at Bank of China, Industrial and Commercial Bank of China, China Construction Bank, Agricultural Bank of China, China Merchants Bank, and Hong Kong banks. Same FBAR and 8938 framework applies. Wrinkles: U.S.-China tax treaty Article 4 residency tiebreaker, §901 foreign tax credit on Chinese dividend and interest income, beneficial-ownership accounts in Shanghai and Shenzhen where a U.S. person holds signature authority, and Hong Kong's non-treaty status. We unwind through Streamlined Filing Compliance Procedures.
Roche & Veeva §174 R&E + §41 credit
Roche Diagnostics at 4300 Hacienda Drive, Veeva Systems life-sciences cloud-software, and the Hacienda Business Park life-sciences cluster sit on top of the 2017 TCJA §174 mandatory R&E capitalization regime — five-year domestic and fifteen-year foreign amortization starting tax year 2022. The §41 research credit overlays at 20 percent or the 14 percent ASC, with California's R&TC §17052.12 state-credit conformity at 15 percent. We represent individual employees and equity holders on K-1 flow-through and ESPP §423 positions coordinated with corporate research-credit elections.
Mello-Roos CFD (Ruby Hill, Vintage Hills)
Ruby Hill, Vintage Hills, Bridle Creek, and portions of east Pleasanton sit inside Community Facilities Districts formed under the Mello-Roos CFD Act of 1982 at Cal. Gov. Code §53311. The CFD special tax shows on the Alameda County tax bill as a separate line, often $2,000-$8,000 annually for the bond-amortization period. Goldman v. State Bd. of Equalization and Howard Jarvis Taxpayers Ass'n v. Roseville frame the procedural-defect attack under Gov. Code §53341. The Prop 13 base-year and Prop 8 decline-in-value appeals on the ad-valorem portion are usually the better lever.
Prop 8 AAB appeals (Alameda County)
2020-2022 Tri-Valley appreciation pushed Prop 13 base-year values above the post-cooling market across Ruby Hill, Vintage Hills, Castlewood, Foothill, Val Vista, Mohr Park, and downtown Pleasanton. The Alameda County Assessment Appeals Board at 1221 Oak Street, 5th Floor, Oakland handles Prop 8 decline-in-value appeals under R&TC §1603-1611 with a July 2 to September 15 filing window. Informal Decline in Market Value Reassessment is the no-fee preliminary path through the Assessor; formal AAB application follows if the informal review does not produce the right number. Sub-neighborhood comparable sales carry more weight than tract-wide averages.
FTB residency audits (Austin, Reno, Boise exits)
Post-2020 remote-work exits from Pleasanton to Austin, Houston, Reno, Las Vegas, Boise, and Coeur d'Alene pulled Workday, Veeva, ICE Mortgage Technology, Roche, and tech-sector workers across state lines while many kept Ruby Hill, Vintage Hills, Castlewood, Foothill, or Val Vista real estate. The nine-factor domicile test at R&TC §17014 puts those facts under FTB scrutiny. The Appeal of Bragg (2003), Appeal of Bindley (2018), and Corbett v. FTB line of authority frame the analysis. Deferred RSU vests and ESPP purchases after exit can still be California-source under Reg. §17951-5(b).
§132 BART transit fringe
Downtown Pleasanton BART (5709 Bernal Avenue) and Dublin/Pleasanton BART (5801 Owens Court) anchor the Tri-Valley feeder for commute-rail traffic into San Francisco and the Peninsula. IRC §132(f) qualified transportation fringe lets an employer provide up to $315 per month (2024 indexed) in tax-free transit-pass and commuter-vanpool benefits, plus $315 per month for qualified parking. Bay Area employers offer the pre-tax election through Clipper Direct or Edenred. The wage-sourcing question for cross-county work and the SF gross receipts tax exposure for SF-side S-corp owners run separately.
Livermore Valley AVA Schedule C
Pleasanton residents commuting east to Wente Vineyards (5050 Arroyo Road, Livermore), Concannon Vineyard (4590 Tesla Road), Murrieta's Well, McGrail, and Garré for tasting-room, harvest, or vineyard work see Schedule C / 1099-NEC contractor income subject to SE tax under IRC §1401. Vineyard owners and LLC members carry §263A(f) UNICAP through K-1 flow-through; the TTB excise stack under 26 USC §5041 (wine) and §5051 (beer where applicable) sits on the producer side. We handle the individual return for residents on the commuter side.
Pleasanton Race Track 1099 income
The Alameda County Fairgrounds at 4501 Pleasanton Avenue and Pleasanton Race Track operations generate 1099-MISC contractor income for jockeys, exercise riders, grooms, trainers, harness drivers, and fair vendors. Purse winnings and prize money report under IRC §61 with §6041 threshold of $600. Pari-mutuel and W-2G winnings trigger §3402(q) 24 percent withholding above threshold. Gambling-loss deduction under §165(d) is capped at winnings and requires itemizing on Schedule A.
Trust Fund Recovery Penalty
Under IRC §6672, the IRS reaches owners of Pleasanton LLCs and S-corps for unpaid payroll trust funds after Form 4180 interviews. EDD asserts the parallel state piece under Cal. Unemp. Ins. Code §1735. Common with Hacienda Business Park flex-space tenants during seasonal cash compression, downtown Main Street restaurant and retail operators, Stoneridge Shopping Center inline-store franchisees, and Tri-Valley contract-research startups. The criminal companion at IRC §7202 attaches to willful failures to collect or pay over.
Nine common causes of tax debt in Pleasanton
1. RSU vest underwithholding at Workday and Veeva
Federal employers withhold tax on RSU vests at the flat 22 percent supplemental rate. Senior engineers, product managers, sales executives, and finance leads at Workday (6110 Stoneridge Mall Rd), Veeva, ICE Mortgage Technology, and Roche in California's top brackets owe an additional 15 to 20 percent come April. Prior-year balances roll forward into multi-year IAs.
2. ISO exercise AMT trap
Pre-public-offering and early-stage Tri-Valley employees who exercise Incentive Stock Options trigger AMT on the spread between strike and FMV under IRC §56(b)(3). The AMT can hit six figures in the exercise year even when no shares are sold — cash to pay must come from somewhere, and the §53 minimum-tax credit recovery runs out over future years subject to caps.
3. ESPP §423 ordinary-income shock
Workday, Veeva, and Roche ESPP plans under §423 produce ordinary-income recognition on the 15 percent purchase discount plus capital-gain treatment on the appreciation between purchase and sale. Disqualifying dispositions before the qualifying holding period (two years from grant, one from purchase) recharacterize the gain as ordinary — multiplying the California 13.3 percent state tax on top.
4. Unreported FBAR exposure
Pleasanton residents who emigrated from India or China and retained ICICI / HDFC / SBI / Bank of China / ICBC / CCB accounts past the $10,000 threshold without filing FinCEN Form 114 face $10,000 per-account-per-year non-willful penalties under 31 USC §5321 and the greater-of-$100,000-or-50-percent willful penalty on actual non-disclosure. Streamlined Filing Compliance Procedures resolve most cases.
5. FTB residency audit after Tri-Valley exit
Tech and pharma workers relocating from Pleasanton to Austin, Reno, Boise, Coeur d'Alene, or Las Vegas often retain a Ruby Hill, Vintage Hills, Castlewood, or Foothill home — all factors the FTB weighs to assert continuing California domicile under R&TC §17014. Deferred RSU vests and ESPP purchases post-exit can still be California-source.
6. Quarterly-estimate shortfall (1099 contractors)
Hacienda Business Park 1099 contract scientists, contract software engineers, marketing consultants, and Tri-Valley independent contractors underestimate quarterly Form 1040-ES and FTB 540-ES payments. SE tax under IRC §1401 plus federal and California income tax stack on net Schedule C, and a single year of underestimation rolls into multi-year balance once interest and §6654 penalty compound.
7. CalSTRS + §403(b) AMT exposure
Pleasanton Unified teacher households with CalSTRS pensions, §403(b) deferrals, and spousal income from Workday, Veeva, or Roche can land in AMT or §1411 net-investment-income-tax territory. Underwithholding from the spouse plus federal-FTB stacking creates April balances that pull from after-tax savings.
8. CDTFA sales-tax exposure (Stoneridge retail)
Stoneridge Shopping Center anchor and inline retailers, Hacienda Business Park flex-space tenants, downtown Main Street boutiques, and Pleasanton restaurant operators carry CDTFA sales-tax exposure when collected sales tax is not remitted. Personal dual-determinations under R&TC §6829 reach corporate officers and LLC members. Audit-period assessments can stretch back three to eight years.
9. ERC clawback exposure
Employee Retention Credit claims filed by promoter mills for Pleasanton Hacienda Business Park flex-space operators, Stoneridge retail, downtown restaurants, and Tri-Valley contract-research startups are being clawed back through CP207 and CP207L letters under the IRS Voluntary Disclosure Program and follow-on audits.
Who is on the hook: eight Pleasanton 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 Pleasanton spouse can be pursued for the entire balance — even post-divorce — subject to Innocent Spouse Relief under IRC §6015 and R&TC §18533.
Divorce and tax allocation at Alameda County Superior Court
The East County Hall of Justice at 5151 Gleason Drive, Dublin handles Pleasanton-area family-law matters, with the René C. Davidson Courthouse at 1225 Fallon Street, Oakland as the main county civil venue. Allocation of joint federal liability, Workday and Veeva RSU treatment as community property, Roche and ICE Mortgage Technology equity holdings, and stock-option division under Marriage of Hug all bear on the tax case. We coordinate with family-law counsel.
Responsible persons for payroll trust funds
TFRP under IRC §6672 reaches anyone with check-signing authority who willfully failed to pay over withheld taxes. IRC §7202 criminal exposure attaches to willful failure to collect or pay over — Hacienda Business Park flex-space tenant principals, downtown Main Street restaurant operators, Stoneridge inline-retail franchisees, and Tri-Valley contract-research startup officers all carry this risk. EDD's state TFRP analog is at UIC §1735.
CDTFA dual-determinations
CDTFA can issue personal dual-determinations against corporate officers, directors, and LLC members for unremitted sales tax under Cal. Rev. & Tax. Code §6829. Common with Stoneridge Shopping Center, downtown Main Street, and Hacienda Business Park retail and restaurant groups.
FTB suspended-entity exposure
A Pleasanton LLC suspended by FTB under R&TC §23301 loses its right to contract or defend in California courts. Officers signing on behalf may incur personal exposure. Common with single-member service LLCs and Tri-Valley contract-research startups that miss the $800 minimum franchise tax during downcycles. Revive via Form 3557 once compliance is current.
Transferee liability (Prop 19, family transfers)
IRC §6901 reaches transferees where the transfer rendered the transferor insolvent and tax debt remains. Common with Prop 19 parent-child transfers of Pleasanton real estate since the February 2021 effective date. The post-2021 limit on the parent-child exclusion to primary residences pulled most second-home, rental, and investment-property transfers in Ruby Hill, Vintage Hills, and Castlewood into reassessment at the Alameda County Assessor.
Successor business liability
Asset purchases continuing a seller's Pleasanton operation can carry CDTFA successor liability under R&TC §6811-6814 and EDD successor liability under UIC §1731. Buyers protect with CDTFA clearance letters before close — especially on Main Street restaurant and retail acquisitions, Stoneridge inline-store transfers, and Hacienda Business Park flex-space asset deals.
Estate and decedent returns
California has no state estate tax, but federal estate-tax planning under §2010 (unified credit), the §6166 estate-tax installment plan, the QTIP election under §2056(b)(7), and the stepped-up basis at death under §1014 are the central planning levers for Pleasanton estates with appreciated Ruby Hill, Vintage Hills, Castlewood, or Foothill real property. The decedent's final 1040, the estate's 1041, and personal liability under 31 USC §3713(b) for premature distributions all attach to the executor.
What resolution can look like in Pleasanton
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. 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 during tech-sector downturns, pharma-sector layoffs, post-divorce recovery periods, and family-bereavement events.
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 2020 SCU Lightning Complex smoke closures, COVID-era Hacienda Business Park shutdowns, PG&E PSPS events, and serious illness. FTB waivers under §19131 and §19132 follow parallel principles. FBAR penalty mitigation through the Streamlined procedures runs separately.
Liens and levies released
A federal NFTL recorded with the Alameda County Clerk-Recorder withdraws once a streamlined IA is in place under Fresh Start. FTB State Tax Liens release on payment, compromise, or release-for-cause. Wage and bank levies stop when the matter moves to CNC, IA, or OIC processing.
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 Pleasanton tax matter
A Pleasanton tax matter rarely sits in one forum. A federal RSU underwithholding bill at Workday or Veeva triggers a parallel California assessment within four years through the federal-state information-exchange agreement. An ISO exercise at a pre-public Tri-Valley startup creates a federal AMT preference under §56(b)(3) and a California §17062 conformity question on the state side. An ICICI or Bank of China FBAR exposure crosses IRS Large Business & International FBAR examination, IRS Criminal Investigation review under 31 USC §5322, FinCEN administrative enforcement, and FTB residency factors in the same engagement. A Hacienda Business Park flex-space tenant carries CDTFA sales tax, EDD payroll, FTB income, and city business-license matters at once. A Ruby Hill or Vintage Hills Mello-Roos challenge intersects Government Code §53341 procedural-defect analysis with the parallel Prop 8 decline-in-value AAB appeal at 1221 Oak Street. A Pleasanton-to-Austin or Pleasanton-to-Reno exit puts Bragg, Bindley, Corbett, Reg. §17951-5(b), and deferred-RSU sourcing on the same audit file. These matters do not stay in their lanes.
Victory Tax Lawyers is admitted in California, headquartered in Los Angeles, and built around this overlap. Parham Khorsandi (Cal Bar #266658) and Amir Boroumand (Cal Bar #269570) appear directly before the FTB, CDTFA, EDD, and OTA, and on the federal side before the IRS and the U.S. Tax Court. The same attorneys handle the whole engagement — no Form 2848 workaround, no referral chain through out-of-state counsel.
California Rule of Professional Conduct 7.1 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. This page does not promise outcomes, does not promote dollar averages, and does not list testimonials without context.
If your case is purely federal — an IRS audit, a Tax Court petition with San Francisco place of trial, an Offer in Compromise, an FBAR Streamlined Filing — we handle it under Tax Court bar admission, Circular 230, and a Form 2848 Power of Attorney. The California-licensed difference shows up when the state side appears, which it usually does in Pleasanton.
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 realistic resolution options.
Engagement letter
A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law 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. Notices route to counsel.
Transcript investigation
IRS Account Transcripts, Wage-and-Income Transcripts, and Record of Account pulled across all open years. FTB MyFTB, CDTFA, 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, Streamlined FBAR Filing, or Tax Court petition with the FTB, CDTFA, or EDD parallel strategy where applicable.
Resolution filed
Federal Forms 656, 433-A, 9423, 12153, FinCEN Form 114, Form 8938, 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, FBAR annual filings going forward, and protection against IA default. 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 has ten years from the date of assessment to collect. After the federal Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Tolling events extend the federal CSED: a pending OIC (extends by OIC pendency plus 30 days), bankruptcy (extends by stay plus six months), Collection Due Process hearings, 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 assessment, due date, or final return filing to collect — double the federal CSED. CDTFA collection runs 10 years under §6711 with similar tolling. EDD operates under its own collection window in the Unemployment Insurance Code.
A federal Pleasanton balance assessed in 2016 may approach 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. The two strategies are decided together.
Pleasanton venue: federal and state tax forums
A Pleasanton tax matter may proceed in any of several federal or state forums depending on the type of liability. Below are the offices, courthouses, and agencies serving the city.
U.S. Tax Court — San Francisco trial sessions
The United States Tax Court holds Northern California trial sessions at the Phillip Burton Federal Building and U.S. Courthouse, 450 Golden Gate Avenue, San Francisco CA 94102. A Pleasanton petitioner designates "San Francisco, California" as the place of trial on the petition under Tax Court Rule 140. Sacramento at 501 I Street is an alternative where docket timing favors it.
IRS Oakland Taxpayer Assistance Center
The IRS operates a TAC at 1301 Clay Street, Oakland CA 94612, inside the Ronald V. Dellums Federal Building — roughly 27 miles west of Pleasanton via I-580 through Castro Valley. Appointments through apps.irs.gov/app/office-locator or 844-545-5640. For most resolution work, in-person visits are not required — we represent clients by Form 2848 PoA and route notices directly to counsel.
U.S. District Court — NDCA, Oakland Division
Federal refund suits and criminal-tax cases proceed in the U.S. District Court for the Northern District of California, Oakland Division, at the Ronald V. Dellums Federal Building, 1301 Clay Street, Oakland CA 94612. The San Francisco Division sits at the Phillip Burton Federal Building, 450 Golden Gate Avenue. The San Jose Division sits at the Robert F. Peckham Federal Building, 280 South First Street. Appellate review goes to the Ninth Circuit at 95 Seventh Street in San Francisco.
FTB Oakland Field Office (1515 Clay St)
The California Franchise Tax Board Oakland Field Office is at 1515 Clay Street, Suite 305, in the Elihu M. Harris State Office Building — the home FTB office for Pleasanton residents and businesses: residency audits under R&TC §17014, Notice of Proposed Assessment protests, FTB Settlement Bureau review under §19443, and walk-in services for individual taxpayers.
CDTFA Oakland District Office
The California Department of Tax and Fee Administration Oakland District Office at 1515 Clay Street, Suite 303 serves Alameda County including Pleasanton. Petitions for Redetermination, appeals conferences, and offer reviews route through this office for sales-tax, use-tax, and fuel-tax work. Verify current address through cdtfa.ca.gov/office-locations.htm before any walk-in visit.
Alameda County Superior Court — East County
The Alameda County Superior Court East County Hall of Justice at 5151 Gleason Drive, Dublin CA 94568 is the closest county venue for Pleasanton residents. The René C. Davidson Courthouse at 1225 Fallon Street, Oakland is the main county civil and family-law venue. State-tax civil collection actions, divorce-tax allocation, R&TC §19382 / §19385 refund suits, and probate-tax matters proceed at one of the two depending on case type.
Alameda County Assessor & AAB (1221 Oak St)
The Alameda County Assessor at 1221 Oak Street, Oakland CA 94612 administers Prop 13 base-year values, Prop 19 parent-child transfers, supplemental assessments, and the property roll across Pleasanton. The Assessment Appeals Board at the Clerk of the Board, County Administration Building, 5th Floor, 1221 Oak Street, hears reassessment petitions under R&TC §1603-1611. Alameda County uses the September 15 filing deadline for the regular roll.
Alameda County Treasurer-Tax Collector
The Alameda County Treasurer-Tax Collector at 1221 Oak Street, Oakland, handles property-tax billing and collection across the county. Pleasanton property-tax delinquencies on Ruby Hill, Vintage Hills, Castlewood, Foothill, Val Vista, Mohr Park, and downtown parcels proceed through this office. Mello-Roos CFD special-tax bills on Ruby Hill, Vintage Hills, and Bridle Creek parcels appear as separate lines on the same bill.
California Office of Tax Appeals
The California Office of Tax Appeals is headquartered in Sacramento at 400 R Street with a Southern California hearing room at 355 South Grand Avenue, Los Angeles and a San Francisco hearing room. Video appearance is the practical option for most Pleasanton matters. OTA petitions follow a 30-day window from an FTB or CDTFA Notice of Action under R&TC §19045 / §19324.
California Court of Appeal, First District
Appeals from Alameda County Superior Court go to the California Court of Appeal, First Appellate District, at 350 McAllister Street, San Francisco CA 94102 — the appellate division serving the Bay Area counties through Divisions One through Five.
City of Pleasanton — business license & TOT
The City of Pleasanton administers the business-license tax under Pleasanton Municipal Code Chapter 5 from City Hall at 200 Old Bernal Avenue, Pleasanton CA 94566. Pleasanton imposes a transient occupancy tax on hotels and short-term lodging. Hacienda Business Park flex-space tenants, Stoneridge Shopping Center retailers, downtown Main Street operators, home-based contractors, and rental-property owners all need current business licenses on file with the Finance Department.
Alameda County Clerk-Recorder
The Alameda County Clerk-Recorder at 1106 Madison Street, Oakland records federal Notices of Federal Tax Lien under IRC §6323, FTB State Tax Liens under Cal. Gov. Code §7171, deeds of trust, satisfaction-of-mortgage filings, and quitclaim transfers across the county. Lien release, certificate of discharge, subordination, and withdrawal filings on Pleasanton parcels route through this office.
Request a free consultation with a Pleasanton tax attorney
A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, last filed federal and California returns, any FTB or CDTFA or EDD correspondence, and — if you work at Workday, Veeva, Roche, ICE Mortgage Technology, or elsewhere in the Hacienda Business Park, run a Stoneridge or downtown Pleasanton business, hold accounts at ICICI / HDFC / SBI / Bank of China / ICBC / CCB, own Ruby Hill or Vintage Hills property, or own a Livermore Valley wine interest — your most recent W-2, 1099, K-1, Schedule E, Schedule C, RSU and option statements, ESPP confirmations, and foreign-account statements. We will tell you which resolution options fit your facts on both sides before you sign anything.
Principal office: 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Statewide California service including Pleasanton and all of Alameda County.
Frequently asked questions — Pleasanton
Author & reviewer
Written by Amir Boroumand, Esq.
Managing Attorney · California Bar #269570 · Admitted to the United States Tax Court
Amir Boroumand is a managing attorney of Victory Tax Lawyers, LLP, headquartered at 1100 S. Robertson Boulevard in Los Angeles. His practice covers federal and California tax controversy across the state, including Pleasanton matters: Workday and Veeva RSU, ISO, AMT, and ESPP §423 representation for the Stoneridge Mall Road headquarters workforce and the Owens Drive life-sciences SaaS workforce; Roche Diagnostics pharma R&E and equity-compensation work for the 4300 Hacienda Drive employee population; ICE Mortgage Technology equity-comp at 1 Ellie Mae Way; §1202 QSBS planning for early-stage Tri-Valley founders; FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing Compliance Procedure work for the Pleasanton Indian-American community (ICICI, HDFC, State Bank of India, Axis, Kotak Mahindra) and Chinese-American community (Bank of China, ICBC, China Construction Bank, Agricultural Bank, China Merchants); Mello-Roos CFD review for Ruby Hill, Vintage Hills, and Bridle Creek parcels; Prop 8 decline-in-value appeals at the Alameda County Assessment Appeals Board (1221 Oak Street, September 15 deadline); FTB residency audits following moves to Austin, Reno, Boise, and Coeur d'Alene; Tri-Valley BART transit-fringe and cross-county wage-sourcing matters; Livermore Valley AVA Schedule C tasting-room and harvest 1099 work; Alameda County Fair and Pleasanton Race Track 1099 jockey, vendor, and concessionaire returns; City of Pleasanton business-license and transient-occupancy tax matters; and U.S. Tax Court petitions designated to the San Francisco trial city.
Last Reviewed:
Reviewed by Parham Khorsandi, Esq.
Managing Attorney · California Bar #266658 · Pepperdine Caruso School of Law, JD 2009
Reviewed for accuracy of California statutory citations (R&TC, UIC, Government Code, Streets & Highways Code), federal Internal Revenue Code citations, named California and federal entities (FTB Oakland, CDTFA Oakland, OTA, Alameda County AAB, IRS Oakland TAC, NDCA Oakland Division, U.S. Tax Court San Francisco, City of Pleasanton at 200 Old Bernal Avenue, Alameda County Superior Court East County Hall of Justice in Dublin), FBAR and Form 8938 framework citations (31 USC §5314, IRC §6038D, IRC §1297, 31 CFR §1010.350), and consistency with California Rule of Professional Conduct 7.1 on lawyer advertising. Dual-attorney review is the firm's standard for geographic-practice content.
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, FinCEN, 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) and federal IRS / U.S. Tax Court matters are handled directly by the firm. Workday, Veeva, Roche, and ICE Mortgage Technology RSU, ISO, ESPP, and AMT planning, §1202 QSBS work, FBAR and Form 8938 cross-border compliance for Indian-American and Chinese-American clients, Mello-Roos CFD review, Prop 8 decline-in-value AAB appeals, FTB residency audits, and Livermore Valley AVA Schedule C work each require accurate underlying documentation. 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 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
Alameda County
County hub
California Tax Attorney
State hub — all 58 counties
Livermore
Tri-Valley neighbor
Livermore
Tri-Valley neighbor
Areas We Serve
Statewide service area