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Tax Attorney in Sacramento County
Federal IRS and California state tax representation for taxpayers across Sacramento County — from the capital itself to Elk Grove, Folsom, Rancho Cordova, Citrus Heights, Galt, and Isleton. Our California Bar-admitted attorneys handle IRS audits, FTB collection cases originating out of the agency's Rancho Cordova headquarters, CalPERS and CalSTRS pension-distribution disputes, state-agency 1099 contractor reclassification, UC Davis Health physician-faculty equity compensation, U.S. Tax Court petitions designated to Sacramento, CDTFA determinations, and EDD payroll audits. Headquartered in Los Angeles at 1100 S. Robertson Boulevard, with direct phone and secure-portal coverage for all of Sacramento County.
By Parham Khorsandi, Esq. — California Bar #266658. Admitted to practice before the United States Tax Court. Last Reviewed: .
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Sacramento County taxpayers facing IRS or FTB collection: the capital region has its own pressure points
Sacramento County is the only county in California where the FTB's own headquarters sits inside the county line — the agency operates out of 9646 Butterfield Way in Rancho Cordova, with the secondary 9645 Butterfield Way collections building across the parking lot. That proximity matters: complex residency, hardship, and compromise files routed up the chain inside FTB often touch personnel sitting two miles from the taxpayer's home. Three pressures dominate the local docket. First, CalPERS and CalSTRS pension-distribution tax problems hit retired state employees in Folsom, Carmichael, and Fair Oaks — lump-sum elections under IRC §402, missed Required Minimum Distributions under IRC §401(a)(9), and the federal-versus-California treatment of public-pension contributions made on a pre-tax basis. Second, state-agency 1099 contractor reclassification under Cal. Lab. Code §2775 is being applied to consultants billing CalHHS, CDPH, CDSS, and other departments through the state contracting system — the EDD audits these aggressively. Third, UC Davis Health physician-faculty members in Davis and along the I-80 corridor walk in with Alternative Minimum Tax exposure from incentive-stock-option exercises at affiliated medical-device companies, plus residency-allocation problems on multi-state academic appointments.
$100M+
Total tax relief secured
2,000+
Tax cases resolved
5.0
Average rating · 72 reviews
CA-Based
LA HQ, serving all of Sacramento County
Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.
A California firm representing Sacramento County taxpayers across the capital region
Victory Tax Lawyers, LLP is a California-licensed tax-law firm with its principal office at 1100 S. Robertson Boulevard in Los Angeles. Both attorneys hold the State Bar of California license in active standing — Parham Khorsandi, Cal Bar #266658, and Amir Boroumand, Cal Bar #269570 — and both are admitted to practice before the United States Tax Court. Because we are California-admitted, we appear directly before the FTB, CDTFA, EDD, and the California Office of Tax Appeals on behalf of Sacramento County clients. The geography is convenient too: U.S. Tax Court holds trial sessions in Sacramento itself, the FTB headquarters sits in Rancho Cordova, and the IRS Sacramento Taxpayer Assistance Center on Watt Avenue covers most of the county.
Sacramento County has a tax-controversy profile shaped by state government. The county hosts roughly 1.6 million residents across seven incorporated cities — Sacramento (county seat and state capital), Elk Grove, Folsom, Citrus Heights, Rancho Cordova, Galt, and Isleton — plus unincorporated communities like Carmichael, Fair Oaks, Orangevale, North Highlands, Arden-Arcade, Antelope, and the Pocket/Greenhaven district. The state workforce concentration is unlike any other California county: tens of thousands of state employees draw paychecks from CalHR, attend retirement seminars run by CalPERS, and either contract with or sit across the table from FTB, CDTFA, EDD, the Office of Tax Appeals, the Board of Equalization, and dozens of cabinet agencies clustered downtown. The tax problems that come out of that workforce look different from the problems in Los Angeles or Orange County.
For Folsom, El Dorado Hills-adjacent, and Granite Bay-edge clients along the I-80 and Highway 50 corridors, the tax work concentrates on Intel Folsom equity compensation (ISOs and RSUs with AMT exposure under IRC §55), VSP Vision Care executive compensation, Apple Sacramento-area data-center contractor classification, and the Sutter Health / UC Davis Health / Kaiser Permanente Roseville-region physician-faculty matters that straddle the Sacramento-Placer county line. For state-employee households — the dominant population in Carmichael, Fair Oaks, Citrus Heights, and parts of Sacramento itself — the work is CalPERS lump-sum tax planning, defined-benefit pension distribution disputes, the federal-versus-state treatment of pre-tax employee contributions under IRC §414(h)(2), FTB residency audits on retirees moving out of California, and the unusual situation where a state employee with a tax problem has the FTB sitting two miles away. For Elk Grove and Galt small-business owners, the work is the same as elsewhere in California: TFRP, EDD AB 5 audits, CDTFA cash-business determinations, and back-tax balances.
The rest of this page lays out the federal and California overlap as it applies to Sacramento County: the courthouses where these matters are heard, the IRS Taxpayer Assistance Center on Watt Avenue, the County Department of Finance and Assessor offices that handle Sacramento County property-tax exposure, the FTB headquarters sitting in Rancho Cordova, and the specific federal and state pressure points that hit capital-region filers.
Your tax rights as a Sacramento County taxpayer
Federal taxpayer rights are codified across the Internal Revenue Code and summarized in IRS Publication 1, the Taxpayer Bill of Rights. California layers its own taxpayer-rights regime on top, primarily through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel provisions for CDTFA and EDD. The major rights you can invoke in a Sacramento County tax matter:
Right to representation (federal)
Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview if you state you wish to consult an authorized representative. A signed Form 2848 puts your tax attorney between you and the IRS for the remainder of the matter. The IRS Sacramento Taxpayer Assistance Center on Watt Avenue honors this at the in-person counter.
Right to representation (California)
FTB Form 3520-PIT (or 3520-BE for entities) appoints a representative with full authority before the Franchise Tax Board. CDTFA Form 392 and EDD DE 48 do the same for sales-tax and payroll matters. Once filed, all FTB Rancho Cordova headquarters notices route to counsel.
Right to Collection Due Process
After a Notice of Federal Tax Lien (IRC §6320) or a Final Notice of Intent to Levy (IRC §6330), you have 30 days to request a Collection Due Process hearing on Form 12153. CDP requests pause federal collection enforcement and preserve U.S. Tax Court review.
Right to OTA appeal
Effective 2018 under AB 102, the California Office of Tax Appeals hears appeals from FTB, CDTFA, and EDD determinations. The appeal window is 30 days from the Notice of Action for FTB matters. Sacramento County cases are heard at OTA Sacramento at 400 R Street, three blocks from the Capitol — the closest OTA hearing location to FTB headquarters.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Sacramento County petitioners typically designate Sacramento as the place of trial — the Tax Court holds sessions at the Robert T. Matsui U.S. Courthouse at 501 I Street. Calendared sessions run several times per year.
Right to a federal OIC
Under IRC §7122, the IRS may accept less than the full liability where doubt as to collectibility, doubt as to liability, or effective tax administration justifies settlement. Filed on Form 656 with Form 433-A(OIC) or 433-B(OIC).
Right to a California OIC
FTB has compromise authority under Cal. Rev. & Tax. Code §19443. CDTFA operates a parallel offer program under Cal. Rev. & Tax. Code §6832. EDD compromise authority sits at Cal. Unemp. Ins. Code §1192. Each program has its own form, financial-disclosure standard, and review track.
Right to a Collection Statute
IRC §6502 gives the IRS 10 years from assessment to collect. California's parallel period under Cal. Rev. & Tax. Code §19255 is 20 years — double the federal CSED. Pull both transcripts before negotiating.
How Victory Tax Lawyers helps Sacramento County taxpayers
Federal & California Offer in Compromise
We prepare and file federal Form 656 with Form 433-A(OIC) under IRC §7122, and FTB Form 4905 PIT or BE with the parallel California financial under Cal. Rev. & Tax. Code §19443. Sacramento County OICs that originate inside FTB headquarters go through the same compromise unit that sits at 9646 Butterfield Way — the two reviews run in parallel but use different Reasonable Collection Potential math. California is generally tougher on equity in primary residences than the IRS, which matters for Folsom and El Dorado Hills-adjacent home equity.
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. State employees with a CalPERS pension stream often have predictable disposable-income math that helps with IA negotiation.
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 Sacramento County real and personal property and record at the Sacramento County Clerk-Recorder. 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. State employees with security-clearance or fiduciary-position requirements often need the NFTL removed for employment reasons.
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. State-employee wages are reachable by both the IRS and the FTB — coordinating release with the State Controller's Office payroll cycle prevents a missed paycheck.
Audit and exam defense
Federal correspondence, office, and field audits. FTB residency audits under Cal. Rev. & Tax. Code §17014 — especially common after a state retiree moves from Carmichael or Fair Oaks to Reno, Las Vegas, or Boise. CDTFA sales-tax audits on Sacramento and Elk Grove restaurants and dispensaries. EDD AB 5 audits on state-agency-adjacent consulting firms and Folsom-area tech contractors.
Penalty abatement
Federal First-Time Penalty Abatement and reasonable-cause requests under IRC §6651. FTB penalty waivers under Cal. Rev. & Tax. Code §19131 (failure to file) and §19132 (failure to pay), and CDTFA waivers under §6592. Reasonable-cause for Sacramento County filers affected by the January 2017 Oroville Dam spillway crisis evacuation, 2021 Caldor Fire smoke and evacuation impact on the Highway 50 corridor, and the 2023 atmospheric-river flooding along the Sacramento and American Rivers.
12 types of Sacramento County tax issues we handle
Federal and California state practice areas, framed for the matters that walk in the door from Sacramento, Elk Grove, Folsom, Citrus Heights, Rancho Cordova, Carmichael, Fair Oaks, and the rest of the county.
CalPERS pension distribution tax
Lump-sum-versus-annuity elections at retirement, the 20 percent federal mandatory withholding on eligible rollover distributions under IRC §3405, Required Minimum Distributions under IRC §401(a)(9), and 50 percent excise penalty exposure for missed RMDs under IRC §4974 (reduced to 25 percent or 10 percent under SECURE 2.0). Common for retired Sacramento-area state workers in Carmichael, Fair Oaks, and Folsom.
CalSTRS and supplemental defined-benefit issues
Sacramento County school districts (SCUSD, Elk Grove Unified, San Juan Unified, Folsom Cordova Unified, Twin Rivers Unified, Natomas Unified) employ tens of thousands of CalSTRS members. Distribution-tax treatment, the Defined Benefit Supplement, Cash Balance Benefit program, and the federal Windfall Elimination Provision and Government Pension Offset all interact with the 1040.
State-agency 1099 contractor reclassification
Consultants billing CalHHS, CDPH, CDSS, DGS, CHHS-Agency departments, and the California State University system as 1099 independent contractors face reclassification under the AB 5 ABC test at Cal. Lab. Code §2775. EDD audits, IRS SS-8 determinations, and the resulting back-payroll exposure all coordinate through the same engagement.
FTB residency audits
The nine-factor domicile test under Cal. Rev. & Tax. Code §17014 and FTB Pub. 1031. Common after moves from Folsom, El Dorado Hills-adjacent, Granite Bay-edge, Carmichael, and Fair Oaks to Reno, Sparks, Las Vegas, Boise, Coeur d'Alene, and Bend. State retirees moving out of California with continued CalPERS payments still get federal Form 1099-R but California cannot tax non-resident pension income under 4 USC §114 — documentation of the move matters.
Trust Fund Recovery Penalty
Under IRC §6672, the IRS pierces the corporate veil for unpaid payroll trust funds. Elk Grove and Galt restaurants, Rancho Cordova warehouse and logistics operators, and Sacramento downtown professional-services firms that fell behind on Form 941 deposits often discover this through Form 4180 interviews. EDD parallel exposure runs under Cal. Unemp. Ins. Code §1735.
EDD AB 5 worker-classification
Folsom-corridor tech consultants, Sacramento marketing and PR firms (many serving state-agency clients), Elk Grove construction subcontracting, real-estate brokerages, healthcare staffing, and beauty-services operators reclassified from 1099 to W-2 under the Dynamex ABC test now codified at Cal. Lab. Code §2775. Back UI, ETT, SDI, and PIT withholding for three years plus penalties.
CDTFA cash-business audits
Sacramento and Elk Grove restaurants, food trucks along R Street and in midtown, dispensaries operating under Sacramento city's cannabis-business permit program, and convenience stores draw CDTFA mark-up audits using observation tests and POS reconciliation. Test-period methodology gets challenged before it scales.
Wage and bank levies
IRS CP90 / LT11 levies, FTB Earnings Withholding Orders for Taxes (EWOT) under Cal. Rev. & Tax. Code §18670, CDTFA collector levies, and EDD wage garnishments. State-employee wages run through the State Controller's Office; coordinating with SCO payroll cycles is part of any release on a CalHR-paid W-2.
Federal and California tax liens
NFTLs filed with the California Secretary of State and the Sacramento County Clerk-Recorder, and FTB State Tax Liens under Cal. Gov. Code §7170 et seq. Both cloud title on Sacramento County real property until released or withdrawn — a problem mid-escrow on a Folsom, Fair Oaks, or Pocket-Greenhaven sale.
Passport revocation defense
IRC §7345 certifications to the State Department. We work to decertify before travel for Folsom tech executives, state-agency contractors with international consulting work, UC Davis Health faculty with cross-border research collaborations, and Sacramento residents with annual family-visit travel commitments.
Equity compensation back taxes
Intel Folsom engineers with ISO exercises into Alternative Minimum Tax exposure under IRC §55, VSP Vision Care equity participants, Apple Sacramento-area data-center salaried staff with RSU vest spikes, and UC Davis Health affiliated medical-device company stock exposures. Multi-state allocation for employees who changed residency mid-vest.
Innocent Spouse Relief
Federal Form 8857 relief under IRC §6015 and California parallel relief under Cal. Rev. & Tax. Code §18533. California is a community-property state under Cal. Fam. Code §760 — the analysis is fact-heavy, especially in Sacramento County dual-state-employee marriages and in divorces involving CalPERS service-credit division under a Domestic Relations Order.
Nine common causes of tax debt in Sacramento County
1. CalPERS lump-sum retirement elections
A state retiree elects a partial lump-sum distribution at separation, the plan withholds 20 percent federal mandatory under IRC §3405, and the retiree learns at April filing that California layers an additional 10.3 to 13.3 percent on the same dollar. Underpayment penalties under IRC §6654 compound from there.
2. State-employee outside consulting
A state employee picks up consulting work on the side without quarterly estimates. The 1099 income hits the W-2 baseline at the top California marginal rate, the federal SE tax adds 15.3 percent on net earnings, and the April balance arrives with no withholding to cover it. Form 2210 underpayment penalties stack.
3. Tech equity compensation
Intel Folsom engineers exercising ISOs trigger AMT preference items under IRC §55 without a sale. VSP Vision Care and Apple Sacramento-region RSU vests pile ordinary income on a W-2 already in the highest California bracket. The April balance routinely runs six figures for senior staff.
4. Departing-resident FTB audits
High earners and state retirees who moved from Sacramento County to Nevada, Idaho, Arizona, or Texas routinely trip the FTB nine-factor domicile test. The FTB asserts continued California domicile for one to three additional tax years, generating substantial state-tax assessments after the move.
5. CalPERS DRO division at divorce
A Sacramento County divorce divides CalPERS service credit through a Domestic Relations Order. The non-member spouse later draws a distribution, taxed individually, and the original member spouse continues to receive their share. Federal and California tax treatment of separate-interest versus shared-payment DROs creates surprise balances if not modeled correctly at the time of separation.
6. ERC clawback exposure
Employee Retention Credit claims submitted by promoter mills are being clawed back through CP207/CP207L letters. Sacramento hospitality groups, Elk Grove medical and dental practices, Rancho Cordova logistics operators, and Folsom professional-services firms are inside the audit wave.
7. Small-business payroll lapses
An Elk Grove restaurant, Citrus Heights auto shop, Sacramento midtown bar, or Galt agricultural operation stops depositing 941 trust funds during a slow quarter. The IRS asserts TFRP against the owner personally under IRC §6672, and EDD assesses parallel state payroll under Cal. Unemp. Ins. Code §1735.
8. Crypto trading without records
Folsom and Granite Bay-edge tech populations hold heavy crypto exposure. Exchanges issued 1099-K and 1099-MISC reports; the IRS matches them to filed returns and issues CP2000 notices for the gap. FTB pursues the parallel California assessment using the federal data.
9. Disaster-disrupted filing
Filers affected by the 2017 Oroville Dam spillway evacuation order, the 2021 Caldor Fire smoke and Highway 50 evacuation, and the 2023 atmospheric-river flooding along the Sacramento, American, and Cosumnes Rivers missed deadlines. Disaster-zone extensions help, but penalty stacks accumulate fast when the disaster window lapses.
Who is on the hook: eight Sacramento County tax-liability scenarios
Joint filers (community-property state)
California is a community-property state under Cal. Fam. Code §760. Joint federal returns create joint-and-several liability under IRC §6013(d)(3). One spouse can be pursued for the entire balance — even after divorce — subject to Innocent Spouse Relief under IRC §6015 and Cal. Rev. & Tax. Code §18533. Especially relevant in Sacramento County two-state-employee households where one spouse's withholding masks the other's underwithheld outside income.
Partnership general partners
Under IRC §6231 and the BBA centralized partnership audit regime, general partners of Sacramento-area real-estate, agricultural, and professional-services partnerships 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 Elk Grove, Citrus Heights, Sacramento, and Galt small-business owners after the entity folds.
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 Sacramento restaurant operators and Elk Grove retail entities after the business closes.
FTB suspended-entity personal exposure
An entity that fails to pay California minimum franchise tax or file a Statement of Information is suspended by FTB under Cal. Rev. & Tax. Code §23301. While suspended, the entity loses its right to contract, sue, or defend in California courts — including the Sacramento County Superior Court at the Gordon D. Schaber Courthouse. Officers signing on behalf during suspension can incur personal exposure.
Transferee liability
IRC §6901 reaches a transferee of assets where the transfer rendered the transferor insolvent and tax debts remain unpaid. Sacramento County family-LLC restructurings, Prop 19 parent-to-child transfers under Cal. Const. Art. XIII A, and intra-family trust funding moves can trigger this analysis.
Successor business liability
Asset purchases of a Sacramento County restaurant, agricultural operation, or auto-dealership 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 Sacramento County estates — including the high CalPERS-survivor-annuity values common in the capital region — moves through the Sacramento County Superior Court Probate Division at the William R. Ridgeway Family Relations Courthouse.
What resolution can look like in Sacramento County
Debt reduced
An accepted federal OIC settles the IRS liability for less than the full amount. A parallel FTB §19443 compromise can settle the California side — the same compromise unit handles both Sacramento County files and the rest of the state, working out of FTB headquarters in Rancho Cordova. Partial Pay IAs cap recovery at what you can pay through the federal CSED or the FTB 20-year statute. Currently Not Collectible status freezes federal collection while finances stabilize.
Penalties abated
Federal First-Time Penalty Abatement removes failure-to-file and failure-to-pay penalties for a clean compliance year. Reasonable-cause requests address the 2017 Oroville Dam evacuation, 2021 Caldor Fire smoke and evacuation periods, 2023 atmospheric-river flooding, serious illness, and preparer reliance. FTB waivers under §19131 and §19132 follow parallel principles.
Liens and levies released
A federal NFTL withdraws once a streamlined IA is in place under Fresh Start. FTB State Tax Liens release on payment, accepted compromise, or release-for-cause — critical when refinancing or selling Sacramento County real property. Wage and bank levies stop when the account moves to CNC, IA, or OIC processing. State-employee wages levied through the State Controller's Office stop within one payroll cycle of release. Passport certifications reverse once federal debt drops below the §7345 threshold.
Outcomes vary. Past results do not guarantee future outcomes. Each tax case is unique.
Settlement ranges from the firm's case files
The following ranges come from Victory Tax Lawyers cases over the past several years and contribute to the firm's $100M+ aggregate tax-relief figure. Names and identifying facts are removed for confidentiality.
| Matter type | Original liability | Resolution | Approximate result |
|---|---|---|---|
| Installment Agreement | $138,296 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $126,489 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $128,206 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $116,451 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $152,296 | IRC §6159 streamlined IA | $25/month accepted |
Past results do not guarantee future outcomes. Each tax case is unique and turns on facts, asset position, monthly disposable income, IRS Allowable Living Expense tables, FTB equivalent standards, and the discretion of the assigned Revenue Officer, Settlement Officer, or FTB compromise reviewer. Acceptance rates for federal Offer in Compromise vary widely — the IRS reported a nationwide acceptance rate of roughly 30 to 40 percent in recent years.
Why work with a California-licensed firm on a Sacramento County tax matter
Sacramento County taxpayers deal with two tax systems that interact in ways most out-of-state firms do not understand — and the California system is administered from inside the county. A residency adjustment at the FTB headquarters two miles from your home can trigger a federal income re-allocation. A federal NFTL filed with the Sacramento County Clerk-Recorder sits in the same recording index as the FTB's own State Tax Lien against the same Folsom or Fair Oaks property. An IRS Form 4180 interview on an unpaid 941 trust fund often runs in parallel with an EDD payroll audit run out of the same Sacramento employment-tax field office and a CDTFA sales-tax determination on the same Elk Grove or Sacramento business. The matters do not stay in their lanes.
Victory Tax Lawyers is California-admitted, headquartered in Los Angeles, and built around exactly this overlap. Parham Khorsandi (Cal Bar #266658) and Amir Boroumand (Cal Bar #269570) appear directly before the FTB, CDTFA, EDD, and the California Office of Tax Appeals, and on the federal side before the IRS and the U.S. Tax Court. No out-of-state coordination, no Form 2848 workaround. The same attorneys handle the whole engagement from initial Form 12153 through final Tax Court trial in Sacramento.
California is one of the most lawyer-intensive tax environments in the country. The State Bar's Rule of Professional Conduct 7.1 (formerly Rule 1-400) tightly governs lawyer advertising in the state — no superlatives without verifiable substantiation, no specific dollar guarantees, no testimonials without disclaimers. The firm operates under those rules natively, which is why this page does not promise outcomes, does not promote dollar averages without context, and does not list testimonials without proper disclosure.
Sacramento County is also unusual for the state-workforce density driving the practice mix. The CalPERS distribution-tax, CalSTRS supplemental-benefit, state-agency 1099 reclassification, and UC Davis Health physician-faculty equity matters that show up here are not the same matters that walk in the door in San Diego or Orange County. That practice density shapes how we approach a Sacramento County engagement.
The seven steps of a VTL tax-resolution engagement
Free consultation
A 30-minute call with an attorney to outline the facts, the IRS or FTB notices received, and the realistic resolution options for a Sacramento County matter.
Engagement letter
A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law attorney-client privilege both attach.
Federal & state PoA
Form 2848 filed with the IRS, FTB Form 3520, CDTFA Form 392, or EDD DE 48 filed with the relevant California agency. All notices route to counsel.
Transcript investigation
IRS Account Transcripts, Wage-and-Income Transcripts, and Record of Account pulled across all open years. FTB MyFTB account, CDTFA records, and EDD records pulled. Federal CSED and California 20-year statute dates verified.
Strategy memo
A written analysis recommending federal OIC, IA, CNC, audit response, CDP, or Tax Court petition — with the FTB, CDTFA, or EDD parallel strategy where applicable.
Resolution filed
Federal Forms 656, 433-A, 9423, 12153, or Tax Court Petition. State FTB Form 4905, CDTFA offer, or EDD compromise. Negotiations with Revenue Officers, Settlement Officers, Appeals Officers, FTB analysts, CDTFA supervisors, and OTA hearings handled directly.
Compliance close-out
Post-resolution monitoring: quarterly estimates, return filings, and protection against IA default on either side. The case is done when the new pattern is stable, not when the offer is accepted.
Collection statute warning — the California 20-year tail
Under IRC §6502(a), the IRS generally has ten years from the date of assessment to collect a tax. After the federal Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Tolling events that extend the federal CSED include a pending Offer in Compromise (extends by OIC pendency plus 30 days), bankruptcy filing (extends by bankruptcy stay plus six months), Collection Due Process hearings (extends while pending), Innocent Spouse claims, and continuous absence from the United States for six months or more.
The California side is the opposite of forgiving. Under Cal. Rev. & Tax. Code §19255, the FTB has 20 years from the latest of the assessment, the date the liability becomes due and payable, or the date a final return was filed, to collect. That is double the federal CSED. CDTFA collection statutes for sales-and-use tax are governed by Cal. Rev. & Tax. Code §6711, generally 10 years from determination but with similar tolling. EDD has its own collection window under Cal. Unemp. Ins. Code §1701.
The practical impact for a Sacramento County filer: a federal balance assessed in 2016 may be approaching CSED expiration in 2026, while the FTB equivalent continues to be collectible until 2036 — administered from headquarters two miles away in Rancho Cordova. 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, not in isolation.
Sacramento County venue: where federal and state tax matters are heard
Sacramento County is one of the few California counties where federal and state tax venues both sit inside the county line. The U.S. Tax Court holds trial sessions downtown, the FTB administers itself from Rancho Cordova, the IRS Sacramento Taxpayer Assistance Center sits on Watt Avenue, and the Sacramento County Superior Court hears state-tax civil matters at the Gordon D. Schaber Courthouse on 9th Street. State matters at the FTB, CDTFA, and EDD that reach a formal appeal proceed through the California Office of Tax Appeals at its Sacramento hearing location at 400 R Street.
U.S. Tax Court — Sacramento trial sessions
The U.S. Tax Court designates Sacramento as a place of trial under Tax Court Rule 140. Sessions are held at the Robert T. Matsui U.S. Courthouse at 501 I Street, Sacramento 95814. Sacramento County petitioners typically designate Sacramento on the deficiency petition; sessions are calendared several times per year.
IRS Taxpayer Assistance Center — Sacramento
The IRS Sacramento Taxpayer Assistance Center is at 4330 Watt Avenue, Sacramento 95821. Appointments are required and arranged through apps.irs.gov/app/office-locator or 844-545-5640. The TAC handles in-person account inquiries, payment intake, identity verification, and ITIN applications.
Sacramento County Department of Finance / Tax Collector
The Sacramento County Department of Finance, Tax Collection & Business Licensing at 700 H Street, Room 1710, Sacramento 95814 administers Sacramento County property-tax billing, collection, defaulted-property auctions, and unsecured-roll collections under California Revenue and Taxation Code. Property-tax delinquencies on Sacramento County real property — including those triggered by Prop 13 reassessment changes — route through this office.
Sacramento County Assessor
The Sacramento County Assessor at 3636 American River Drive, Suite 200, Sacramento 95864 sets Prop 13 base-year value and annual assessed value for every parcel in the county. Prop 19 parent-to-child reassessment exclusions, Prop 8 decline-in-value applications, and assessment appeals to the Sacramento County Assessment Appeals Board start here.
Sacramento County Superior Court
The Sacramento County Superior Court's main civil venue is the Gordon D. Schaber Sacramento County Courthouse at 720 9th Street, Sacramento 95814. The court handles state-tax civil actions, FTB and CDTFA collection litigation, judicial review of OTA decisions, probate proceedings with tax components, and divorce matters involving community-property tax allocation and CalPERS DRO division. The William R. Ridgeway Family Relations Courthouse handles the family-law docket; the Lorenzo E. Patino Hall of Justice handles criminal matters.
FTB headquarters — Rancho Cordova
The California Franchise Tax Board headquarters at 9646 Butterfield Way, Rancho Cordova 95827 administers the entire FTB collection and audit infrastructure for the state. Personal-income-tax audits, residency examinations under Cal. Rev. & Tax. Code §17014, corporate franchise-tax matters under Part 11, and the §19443 compromise unit all sit on this campus. Sacramento County is the only California county where FTB enforcement is administered from inside the county.
U.S. District Court — Eastern District of California
Sacramento County sits in the U.S. District Court for the Eastern District of California. Federal refund suits and criminal-tax cases involving Sacramento County defendants proceed at the Robert T. Matsui U.S. Courthouse at 501 I Street, Sacramento 95814 — the same building that houses Tax Court sessions. Appellate review goes to the U.S. Court of Appeals for the Ninth Circuit in San Francisco.
California Office of Tax Appeals
The California Office of Tax Appeals was created in 2018 under AB 102 to hear appeals from FTB, CDTFA, and EDD determinations. Sacramento County matters are heard at OTA Sacramento at 400 R Street, three blocks from the Capitol. Three-judge panels of Administrative Law Judges; decisions are precedential and published.
VTL represents clients in all seven incorporated cities of Sacramento County — Sacramento, Elk Grove, Folsom, Citrus Heights, Rancho Cordova, Galt, and Isleton — and across the unincorporated communities including Carmichael, Fair Oaks, Orangevale, Antelope, North Highlands, Arden-Arcade, Florin, Foothill Farms, Vineyard, Wilton, Herald, Walnut Grove, Courtland, Hood, and Freeport.
Request a free consultation with a Sacramento County tax attorney
A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, your last filed federal and California returns, your CalPERS or CalSTRS distribution paperwork if applicable, and any FTB, CDTFA, EDD, or Sacramento County Department of Finance correspondence. We will tell you which resolution options actually fit your facts — on both the federal and California sides — before you sign anything.
Office: 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Serving all 7 incorporated cities of Sacramento County by phone, secure portal, and in-person by appointment.
Frequently asked questions for Sacramento County taxpayers
Reviewed by
Parham Khorsandi, Esq.
Managing Attorney · California Bar #266658 · Admitted to the United States Tax Court
Parham Khorsandi is the managing attorney of Victory Tax Lawyers, LLP, headquartered at 1100 S. Robertson Boulevard in Los Angeles. His practice focuses on federal and California tax controversy, including Offer in Compromise negotiations before the IRS and FTB, Installment Agreements, Trust Fund Recovery Penalty defense, FTB residency audits, CalPERS and CalSTRS distribution-tax matters, state-agency 1099 reclassification under AB 5, CDTFA sales-tax representation, EDD worker-classification audits, OTA appeals, and litigation before the U.S. Tax Court Sacramento sessions. He has represented Sacramento County individuals and businesses across Sacramento, Elk Grove, Folsom, Citrus Heights, Rancho Cordova, Galt, Carmichael, Fair Oaks, and the rest of the county.
Last Reviewed:
Attorney Advertising. Victory Tax Lawyers, LLP is a California-licensed law firm with its principal office at 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Information on this page is general in nature, may not reflect the most recent legal developments, and does not create an attorney-client relationship. This page is not legal advice. Federal and California tax outcomes depend on individual facts and the discretion of the Internal Revenue Service, the Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, the Sacramento County Department of Finance, the Sacramento 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), Sacramento County property-tax matters, and federal IRS / U.S. Tax Court matters are handled directly by the firm. Consult a licensed attorney about your specific situation before acting on any content on this page. The State Bar of California Rule of Professional Conduct 7.1 requires that lawyer communications not be false or misleading; this page strives to comply with that rule and does not promise specific outcomes.
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Offer in Compromise
IRC §7122 settlement
Installment Agreement
IRC §6159 payment plan
Tax Lien
IRC §6321 release
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IRS exam defense
Penalty Abatement
First-Time and reasonable cause
Back Taxes
Unfiled returns and balances
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