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Tax Attorney in San Bruno, California

What this page covers

  • Federal IRS, U.S. Tax Court, and California FTB / CDTFA / EDD representation for San Bruno taxpayers
  • YouTube global HQ (901 Cherry Ave, Alphabet / Google) plus Walmart eCommerce (850 Cherry Ave) RSU / ISO / §83(b) / AMT / §1202 QSBS / §409A / §415 / §423 ESPP work
  • SFO airline-crew 49 USC §40116(f) Pilots and Flight Attendants Tax Fairness analysis, §911 foreign-earned-income, §107 housing, and multi-state withholding cleanup
  • 2010 San Bruno pipeline disaster settlement classification under IRC §104(a)(2), §139, §61, §1033, and §6511
  • FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing for the Filipino-American community (BDO, BPI, Metrobank, Landbank, PNB) and Chinese-American community (Bank of China, ICBC, CCB)
  • San Mateo County AAB Prop 8 decline-in-value appeals at 400 County Center Redwood City (Sept. 15 deadline)
  • National Archives at San Bruno (1000 Commodore Dr) federal-employee / 1099 contractor, Skyline College adjunct §117(c) and §403(b), and City of San Bruno (567 El Camino Real) CalPERS / §457(b) representation

Federal IRS and California state tax representation for San Bruno taxpayers — from the YouTube global headquarters at 901 Cherry Avenue with the thousands of Google / Alphabet engineers, product managers, creative staff, and ad-platform employees on the campus; the Walmart eCommerce engineering operation at the 850 Cherry Avenue legacy Walmart.com / Walmart Labs / Jet.com complex; the SFO airline crew workforce of pilots, flight attendants, ground operations, and ramp staff based at San Francisco International Airport on the south side of US-101; the federal civil-service and contractor workforce at the National Archives at San Bruno at 1000 Commodore Drive; the Skyline College faculty and adjunct workforce at 3300 College Drive in the College Heights neighborhood; the City of San Bruno municipal workforce at City Hall, 567 El Camino Real, including the Central County Fire Department personnel; the residential corridors of Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, Portola Highlands, and the central San Bruno corridor; the Filipino-American community concentration in Mills Park and Belle Aire with cross-border account exposure at BDO Unibank, BPI, Metrobank, Landbank, and PNB; the Chinese-American community with accounts at Bank of China, ICBC, and China Construction Bank; the surviving and successor population still affected by the September 9, 2010 PG&E Line 132 pipeline rupture in the Crestmoor neighborhood; the BART San Bruno station commute economy on the Red and Yellow lines; and the SamTrans hub adjacency. Our California Bar-admitted attorneys appear at the IRS San Mateo Taxpayer Assistance Center at 977 South Claremont Street, the FTB San Francisco Field Office at 121 Spear Street, the CDTFA San Francisco District Office at 121 Spear Street, the San Mateo County Assessment Appeals Board at 400 County Center Redwood City, 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: .

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San Bruno taxpayers facing IRS collection, FTB assessment, CDTFA audit, FBAR exposure, or county AAB reassessment

If you live or work in San Bruno — the YouTube headquarters on 901 Cherry Avenue with the Google / Alphabet engineering, product, creative, and ad-platform workforce; the YouTube TV operation alongside; the Walmart eCommerce campus at 850 Cherry Avenue running the legacy Walmart.com / Walmart Labs / Jet.com engineering teams; the SFO airline crew base on the south side of US-101 with United, Delta, American, Alaska, Southwest, JetBlue, Air Canada, Lufthansa, ANA, JAL, EVA, Singapore, Cathay Pacific, British Airways, and SkyWest pilots, flight attendants, ground operations staff, and ramp workers; the federal civil-service and 1099 contractor workforce at the National Archives at San Bruno (1000 Commodore Drive); the Skyline College faculty and adjunct team at 3300 College Drive in College Heights; the City of San Bruno government workforce at 567 El Camino Real and the Central County Fire Department personnel; the residential corridors of Crestmoor (still the heart of the 2010 pipeline-disaster recovery), Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, Portola Highlands, and the central San Bruno blocks along El Camino Real; the Filipino-American community concentration in Mills Park and Belle Aire with accounts at BDO Unibank, BPI, Metrobank, Landbank, PNB, and UnionBank; the Chinese-American community with accounts at Bank of China, ICBC, and China Construction Bank; or the BART San Bruno station and SamTrans hub commute population — you sit on a Peninsula city of roughly 43,000 sandwiched between South San Francisco and Millbrae, with SFO airport, the YouTube campus, the 2010 pipeline-disaster footprint, and one of the densest concentrations of Filipino-American residents on the Peninsula. Each thread carries a different federal and California tax profile. This page walks through what San Bruno representation looks like in practice.

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Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.

Why San Bruno tax matters call for a California-licensed firm

San Bruno is a Peninsula city of roughly 43,000 in San Mateo County, sitting immediately south of South San Francisco and immediately north of Millbrae along the US-101 corridor, with ZIP code 94066 covering the city. Connections to the broader Bay Area run US-101 north to San Francisco and south to the Peninsula and San Jose; I-280 from the western edge along Sneath Lane and Skyline Boulevard south to Pacifica and the SF coast; SFO airport on the south side of US-101 within walking distance of Tanforan; BART from the San Bruno station on the Red Line (Richmond – Millbrae) and Yellow Line (Antioch – Millbrae / SFO); SamTrans bus service hubbed at the BART station; and the El Camino Real / SR-82 corridor running the length of the city. The economy is built around several anchors. First, YouTube, LLC — the global video-platform subsidiary of Alphabet Inc. (the public parent of Google) — has its global headquarters at 901 Cherry Avenue, with thousands of engineers, product managers, sales executives, ad-platform staff, creator-relations teams, and YouTube TV personnel on campus. Second, Walmart, Inc.'s eCommerce engineering operation — the former Walmart.com / Walmart Labs / Jet.com complex acquired and consolidated after the 2016 Jet.com deal — has operated at 850 Cherry Avenue. Third, SFO airport on the south side of US-101 is one of the country's busiest international hubs, with United Airlines' second-largest hub, an Alaska Airlines focus city, plus Delta, American, Southwest, JetBlue, Air Canada, Lufthansa, ANA, JAL, EVA, Singapore, Cathay Pacific, British Airways, and regional SkyWest operations — producing a base of pilots, flight attendants, ground-operations crew, ramp workers, and customer-service agents who live in San Bruno because the location is optimal. Fourth, the National Archives at San Bruno at 1000 Commodore Drive is the federal records-storage facility serving California, Hawaii, Nevada, American Samoa, Guam, and the Northern Mariana Islands, with a mix of GS-classified federal employees and 1099 contractors. Fifth, Skyline College at 3300 College Drive (San Mateo County Community College District) serves a Peninsula student body with adjunct, full-time, and administrative faculty. Sixth, the City of San Bruno municipal workforce at 567 El Camino Real plus the Central County Fire Department joint-powers agency (San Bruno, Burlingame, Hillsborough) employs police, fire, public works, library, parks, planning, and finance staff. The residential corridor — Crestmoor (where the September 9, 2010 PG&E Line 132 pipeline rupture killed eight people and destroyed 38 homes at Earl Avenue and Glenview Drive), Rollingwood, Pacific Heights, Mills Park (high Filipino-American concentration), Lomita Park, Belle Aire, Portola Highlands, College Heights, Huntington Park, and the central El Camino Real blocks — houses YouTube and Walmart engineers, SFO airline crew, federal employees, city workers, Filipino-American and Chinese-American families, and the survivors and successor population from the 2010 disaster.

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 San Bruno 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 San Bruno 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 San Mateo Taxpayer Assistance Center at 977 South Claremont Street, the FTB San Francisco Field Office at 121 Spear Street, and the CDTFA San Francisco District Office at the same Spear Street address handle the day-to-day administrative work for San Bruno residents. San Bruno's federal docket runs through the U.S. District Court for the Northern District of California — primarily the San Francisco Division at the Phillip Burton Federal Building (450 Golden Gate Avenue), with some matters routing to the San Jose Division at the Robert F. Peckham Federal Building (280 South First Street) or the Oakland Division at the Ronald V. Dellums Federal Building (1301 Clay Street) depending on case-assignment. 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 21 FAQs answering what San Bruno taxpayers actually ask — including questions specific to YouTube and Alphabet equity, SFO airline crew sourcing, the 2010 pipeline settlement aftermath, and the Filipino-American FBAR profile.

Your tax rights as a San Bruno 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. San Bruno property owners add Prop 13 base-year, Prop 19 parent-child, and Prop 8 decline-in-value protections at the San Mateo 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 YouTube workstation, a Walmart eCommerce desk, an SFO airline-crew base, a National Archives office on Commodore Drive, a Skyline College adjunct office, or a residential address in Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, or Belle Aire.

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 San Bruno address on Cherry Avenue, Earl Avenue, Glenview Drive, Crestmoor Drive, El Camino Real, Sneath Lane, or Skyline Boulevard.

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 YouTube, Walmart, and SFO airline-carrier payroll-account levies during quarterly close periods, and residential bank-account levies on Crestmoor and Rollingwood accounts.

Right to U.S. Tax Court review

A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). San Bruno petitioners commonly designate San Francisco as the place of trial, with sessions held at the Phillip Burton Federal Building at 450 Golden Gate Avenue — roughly 12 miles north via US-101 or accessible by BART from the San Bruno station on the Red and Yellow lines. 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), Los Angeles (355 South Grand Avenue), and San Francisco. Video appearance is the practical option for most San Bruno 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 YouTube and Alphabet RSU positions, Walmart equity holdings, SFO airline-crew base pay, federal-employee GS pay at the National Archives, and Crestmoor / Rollingwood / Pacific Heights home equity differently than the patterns the IRS sees from Central Valley filers.

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 San Bruno resolution.

How Victory Tax Lawyers helps San Bruno 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. Crestmoor and Rollingwood home equity, Pacific Heights view-home equity, Mills Park and Belle Aire home equity, YouTube and Walmart W-2 plus RSU positions, Alphabet equity holdings, SFO airline-crew base pay, and BDO Unibank / BPI / Metrobank / Bank of China / ICBC 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. YouTube and Walmart employees carrying RSU vest underwithholding, SFO airline-crew members with multi-state withholding mismatches, federal contractors at the National Archives with quarterly-estimate shortfalls, and adjunct Skyline College faculty with W-2 / 1099 mixed comp all need a structure that survives San Bruno income volatility.

Lien release and withdrawal

A federal NFTL under IRC §6321 and FTB State Tax Liens under Cal. Gov. Code §7170 attach to San Bruno real property and record with the San Mateo County Assessor-County Clerk-Recorder at 555 County Center, Redwood City. We pursue release after payment, certificate of discharge for sale or refinance, subordination on Crestmoor and Rollingwood 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 YouTube and Walmart payroll accounts, SFO airline-crew direct-deposit accounts at First Republic, Bank of America, Wells Fargo, and Chase, and 1099 receivables for federal contractors and Peninsula independents.

FBAR, Form 8938 & Streamlined Filing

For San Bruno's Filipino-American and Chinese-American communities with cross-border accounts at BDO Unibank, BPI, Metrobank, Landbank, PNB, UnionBank, Security Bank, RCBC, Bank of China, ICBC, China Construction Bank, China Merchants 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 Philippine UITF, PERA, mutual funds, Chinese mutual funds, or Hong Kong pooled 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.

SFO airline crew sourcing & §911

For SFO-based pilots, flight attendants, and check-airmen who live in San Bruno, we run the 49 USC §40116(f) Pilots and Flight Attendants Tax Fairness analysis to determine where state income tax actually attaches when crew is non-resident and flight time is less than 50 percent in any one state. We pursue IRC §911 foreign-earned-income exclusion where the carrier's base-rotation supports a bona fide foreign residence or physical presence claim, the §911(d)(2) housing exclusion, and the multi-state withholding cleanup that follows when a carrier-issued W-2 shows incorrect work-state allocations.

Audit and exam defense

IRS correspondence, office, and field audits handled at the San Mateo TAC at 977 South Claremont Street and the SF TAC at 450 Golden Gate Avenue. FTB residency audits under Cal. Rev. & Tax. Code §17014 on Peninsula departures to Austin, Seattle, Reno, Boise, and Coeur d'Alene. CDTFA sales-tax audits on El Camino Real, Tanforan, and downtown San Bruno retail handled out of the CDTFA San Francisco District Office. EDD employment-tax audits on Peninsula contract workers and San Bruno independent contractors. FBAR examination defense coordinated separately under the IRS Large Business & International division.

2010 pipeline-settlement tax classification

For survivors, decedent families, and homeowners affected by the September 9, 2010 PG&E Line 132 rupture at Earl Avenue and Glenview Drive in Crestmoor, we analyze the federal tax classification of settlement payments and residual trust distributions under IRC §104(a)(2) physical-injury exclusion, IRC §139 qualified disaster-relief payments (FEMA-declared disaster status applies), IRC §61 default-includibility for property-damage above basis, IRC §1033 involuntary-conversion deferral on replacement property (four-year window for federally-declared disasters), and IRC §6511 statute of limitations on amended-return recovery for residual payments now fifteen years out.

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 San Bruno filers affected by the 2010 pipeline disaster, 2017-2019 SF Bay Area PG&E PSPS events, 2020 SCU and CZU Lightning Complex air-quality closures, COVID-era Peninsula office shutdowns, and serious illness or family bereavement.

AAB & Prop 8 decline-in-value appeals

San Bruno Prop 13 base-year values from 2020-2022 purchases often exceed the post-cooling market in Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, Portola Highlands, and the central San Bruno corridor. We file the informal Decline in Market Value Reassessment with the San Mateo County Assessor at 555 County Center, Redwood City and the formal AAB application before the September 15 deadline at 400 County Center. Supplemental and escape-assessment appeals follow their own 60-day filing windows from the supplemental notice.

Twelve tax issues we handle for San Bruno clients

Federal and California state practice areas framed for matters that walk through the door from the YouTube Cherry Avenue workforce, the Walmart eCommerce engineering ranks, the SFO airline-crew base, the National Archives federal employees and contractors, the Skyline College adjunct faculty, the City of San Bruno municipal staff, the Filipino-American and Chinese-American communities, and the residential neighborhoods of Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, Portola Highlands, College Heights, and Huntington Park.

YouTube / Alphabet RSU, ISO & AMT

YouTube HQ at 901 Cherry Avenue runs on Alphabet Inc. (GOOGL / GOOG) RSU and pre-IPO ISO compensation for earlier hires. 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 (pre-IPO Google grants, pre-acquisition YouTube paper, private Alphabet subsidiary equity) 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.

Alphabet §409A & §415 SERP analysis

Alphabet executive compensation profile includes IRC §409A nonqualified deferred compensation arrangements with distribution-timing rules and 20 percent additional tax plus interest under §409A(a)(1)(B) on noncompliant distributions. The §415 limit caps qualified-plan benefits; senior-executive supplemental retirement arrangements run on the SERP side under §409A. FICA-tax timing on NQDC under §3121(v)(2) creates separate exposure on vesting versus distribution. We coordinate the §409A and §415 analysis with the federal and FTB tax position for senior Alphabet employees and retirees.

§1202 QSBS (pre-IPO Google, YouTube founders)

Earliest-stage Google hires and pre-2006 YouTube founders should run IRC §1202 Qualified Small Business Stock eligibility before any disposition of long-held paper. 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. Not applicable to current Alphabet RSU grants because Alphabet has been long-public with gross assets far above the threshold.

SFO airline crew 49 USC §40116(f)

For pilots and flight attendants based at SFO airport on the south side of US-101 from San Bruno, the federal Pilots and Flight Attendants Tax Fairness Act at 49 USC §40116(f) allows a state to tax flight-crew wages only if the crew member is a resident of that state or more than 50 percent of flight time was in that state's airspace by departure and arrival. International long-haul and transcontinental crew often fall below the 50 percent California threshold, which opens an FTB nonresident allocation argument under R&TC §17951. The federal IRC §911 foreign-earned-income exclusion plus §911(d)(2) housing exclusion apply for crew who can establish foreign tax-home and meet bona fide foreign residence or physical-presence tests.

2010 pipeline disaster §104(a)(2) & §139

The September 9, 2010 PG&E Line 132 rupture in Crestmoor killed eight and destroyed 38 homes. Civil-settlement components are classified under IRC §104(a)(2) (personal physical injury, including burn injuries and physical-origin emotional distress, excluded), IRC §139 (FEMA-disaster-qualified relief payments excluded), IRC §61 (property-damage above basis includible), IRC §1033 (involuntary-conversion deferral on replacement property within four years for federally-declared disasters), and IRC §6511 (statute of limitations on amended-return recovery). Residual settlement-trust payments after the 2017 PG&E bankruptcy plan continue to raise classification questions.

FBAR & Form 8938 (BDO, BPI, Metrobank)

San Bruno's Filipino-American community drives a recurring FinCEN Form 114 FBAR and IRS Form 8938 compliance load on BDO Unibank, BPI, Metrobank, Landbank, PNB, UnionBank, Security Bank, and RCBC accounts. Threshold: aggregate foreign accounts over $10,000 at any point in the calendar year triggers FBAR under 31 USC §5314. Philippine UITF, PERA, and mutual-fund holdings 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 San Bruno Chinese-American community holds accounts at Bank of China, ICBC, 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.

National Archives federal-employee + 1099 stack

National Archives at San Bruno at 1000 Commodore Drive employs GS-classified federal employees and 1099 contractors. GS employees participate in TSP under §402(g) elective-deferral limits, FERS defined-benefit pension, Social Security (post-1984 coverage), and FEHB. 1099 contractors carry Schedule C / 1099-NEC income with SE tax at 15.3 percent under §1401, quarterly estimates under §6654, SEP-IRA / Solo 401(k) under §415(c), and §199A QBI analysis subject to SSTB classification. California state tax applies to all wages under R&TC §17041 regardless of federal-employee status.

Walmart eCommerce RSU + severance

Walmart, Inc.'s eCommerce engineering campus at 850 Cherry Avenue issues RSU to senior engineers and director-and-above leadership with 3-5 year vesting. The 22 percent federal supplemental withholding plus California top bracket produces the standard April-balance shortfall. Severance from the 2022-2024 engineering-team consolidations triggers ordinary-income recognition with supplemental withholding. The Walmart 401(k) Plan rollover to IRA on separation runs under §402(c) with the 60-day window. The Walmart Associate Stock Purchase Plan operates under §423.

Skyline College adjunct §117(c) & §403(b)

Skyline College at 3300 College Drive (San Mateo County Community College District) adjuncts carry IRC §117(c) treatment of compensation for required services (fully taxable), §127 employer-provided educational assistance ($5,250 limit), the SMCCCD §403(b) Tax-Sheltered Annuity Plan with §402(g) limits plus the §403(b)(4) 15-years-of-service catch-up, and CalSTRS Cash Balance Benefit Program participation. Adjuncts who pick up 1099-NEC tutoring carry separate Schedule C SE exposure under §1401.

Prop 8 AAB appeals (San Mateo County)

2020-2022 Peninsula appreciation pushed Prop 13 base-year values above the post-cooling market across Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, and Portola Highlands. The San Mateo County Assessment Appeals Board at 400 County Center 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 at 555 County Center; formal AAB application follows if the informal review does not produce the right number.

Trust Fund Recovery Penalty

Under IRC §6672, the IRS reaches owners of San Bruno 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 El Camino Real restaurant and retail operators, Tanforan-area inline-retail franchisees, and Peninsula 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 San Bruno

1. RSU vest underwithholding at YouTube and Walmart

Federal employers withhold tax on RSU vests at the flat 22 percent supplemental rate. Senior engineers, product managers, creative leads, and ad-platform staff at YouTube (901 Cherry Avenue) and Walmart eCommerce (850 Cherry Avenue) in California's top brackets owe an additional 15 to 20 percent come April. Prior-year balances roll forward into multi-year IAs.

2. SFO airline-crew multi-state W-2 mismatch

United, Delta, American, Alaska, Southwest, JetBlue, and the foreign carriers issue W-2s that allocate wages across multiple state withholding columns based on flight time. Crew members find their California column over- or under-stated relative to the 49 USC §40116(f) 50-percent test. The mismatch produces FTB Notices of Proposed Assessment and federal-state reconciliation issues that require Form 540 amendments and FTB protest.

3. ESPP §423 ordinary-income shock

Alphabet, Walmart, and other public-company 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. Alphabet §409A deferred-comp timing

Alphabet's senior-executive nonqualified deferred-compensation arrangements require strict distribution-timing election under §409A. Acceleration, modification outside the §409A(a)(4) rules, or failure to follow the 6-month delay for specified employees triggers a 20 percent additional tax plus interest under §409A(a)(1)(B). FICA timing under §3121(v)(2) is a separate issue.

5. Unreported FBAR exposure

San Bruno residents who emigrated from the Philippines, China, or Hong Kong and retained BDO / BPI / Metrobank / Landbank / PNB / 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.

6. FTB residency audit after Peninsula exit

Tech workers relocating from San Bruno to Austin, Seattle (no state income tax), Reno, Boise, Coeur d'Alene, or Las Vegas often retain a Crestmoor, Rollingwood, Pacific Heights, or Mills Park home — all factors the FTB weighs to assert continuing California domicile under R&TC §17014. Deferred YouTube RSU vests and Alphabet ESPP purchases post-exit can still be California-source.

7. Quarterly-estimate shortfall (1099 contractors)

National Archives 1099 federal contractors, Skyline College adjunct tutoring 1099 work, Peninsula 1099 contract software engineers, marketing consultants, and San Bruno 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.

8. CDTFA sales-tax exposure (El Camino retail)

El Camino Real restaurants, Tanforan and post-Tanforan area retail, downtown San Bruno corridor operators, and small-business tenants on Sneath Lane and San Bruno Avenue 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. Pipeline-settlement misclassification

2010 PG&E Line 132 settlement components — including the residual trust payments still arriving after the 2017 PG&E bankruptcy plan — were sometimes reported on 1099-MISC by PG&E's settlement administrator without proper IRC §104(a)(2) physical-injury exclusion or §139 disaster-relief allocation. Affected San Bruno taxpayers face IRS document-matching notices (CP2000) that need amended returns plus the §6511 statute-of-limitations analysis.

Who is on the hook: eight San Bruno 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 San Bruno 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 San Mateo County Superior Court

The San Mateo County Superior Court Hall of Justice at 400 County Center, Redwood City handles Peninsula family-law matters, including Family Law and Probate divisions. Allocation of joint federal liability, YouTube and Alphabet RSU treatment as community property, Walmart 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 — El Camino Real restaurant operators, Tanforan-area inline-retail franchisees, and Peninsula 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 El Camino Real, Tanforan, and central San Bruno retail and restaurant groups.

FTB suspended-entity exposure

A San Bruno 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 Peninsula 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 Peninsula 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 Crestmoor, Rollingwood, Pacific Heights, and Mills Park into reassessment at the San Mateo County Assessor.

Successor business liability

Asset purchases continuing a seller's San Bruno 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 El Camino Real restaurant and retail acquisitions, Tanforan inline-store transfers, and central San Bruno 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 San Bruno estates with appreciated Crestmoor, Rollingwood, Pacific Heights, or Mills Park 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 San Bruno

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, airline-industry 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 the 2010 pipeline disaster, 2017-2019 SF Bay Area PG&E PSPS events, 2020 SCU and CZU Lightning Complex smoke closures, COVID-era Peninsula office shutdowns, 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 San Mateo 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 San Bruno tax matter

A San Bruno tax matter rarely sits in one forum. A federal RSU underwithholding bill at YouTube or Walmart triggers a parallel California assessment within four years through the federal-state information-exchange agreement. An ISO exercise at a pre-IPO Alphabet subsidiary or pre-2004 Google holding creates a federal AMT preference under §56(b)(3) and a California §17062 conformity question on the state side. An Alphabet §409A deferred-comp distribution misstep produces the 20 percent additional tax federally plus FTB conformity exposure. An SFO airline-crew member's 49 USC §40116(f) sourcing analysis affects both federal and state withholding columns. A BDO Unibank, Bank of China, or Hong Kong 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 2010 pipeline-disaster settlement payment misreported on 1099-MISC triggers both IRS CP2000 document-matching and FTB conformity reconciliation. An El Camino Real restaurant carries CDTFA sales tax, EDD payroll, FTB income, and City of San Bruno business-license matters at once. A federal employee or 1099 contractor at the National Archives carries federal-employee benefit, TSP, and FERS considerations next to W-2 mainline taxation. A Crestmoor or Rollingwood Prop 8 appeal sits at 400 / 555 County Center Redwood City while the parallel FTB residency audit runs at 121 Spear Street. A San Bruno-to-Austin or San Bruno-to-Seattle 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, a 49 USC §40116(f) airline-crew sourcing dispute, or a 2010 pipeline-settlement classification matter — 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 San Bruno.

The seven steps of a VTL tax-resolution engagement

1

Free consultation

A 30-minute call with an attorney to outline the facts, the IRS or FTB notices received, and realistic resolution options.

2

Engagement letter

A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law privilege both attach.

3

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.

4

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.

5

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.

6

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.

7

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 San Bruno 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.

San Bruno venue: federal and state tax forums

A San Bruno 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. Because San Bruno is in San Mateo County (county seat: Redwood City), several county-level forums sit 14 miles south at 400 County Center and 555 County Center.

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 San Bruno 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. BART from the San Bruno station on the Red and Yellow lines reaches Civic Center BART within walking distance of the courthouse.

IRS San Mateo Taxpayer Assistance Center

The IRS operates the closest TAC for San Bruno at 977 South Claremont Street, San Mateo CA 94402 — roughly 5 miles south via El Camino Real or US-101. Alternative venues are the San Francisco TAC at 450 Golden Gate Avenue inside the Phillip Burton Federal Building and the Oakland TAC at 1301 Clay Street inside the Ronald V. Dellums Federal Building. 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, San Francisco / San Jose / Oakland

Federal refund suits and criminal-tax cases proceed in the U.S. District Court for the Northern District of California. 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. The Oakland Division sits at the Ronald V. Dellums Federal Building, 1301 Clay Street. Peninsula cases route primarily to SF based on case-assignment. Appellate review goes to the Ninth Circuit at 95 Seventh Street in San Francisco.

FTB San Francisco Field Office (121 Spear St)

The California Franchise Tax Board San Francisco Field Office is at 121 Spear Street, Suite 400 — the home FTB office for Peninsula 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. The FTB San Jose Field Office at 96 N. Third Street, Suite 600 is the South Bay alternative.

CDTFA San Francisco District Office

The California Department of Tax and Fee Administration San Francisco District Office at 121 Spear Street serves San Mateo County including San Bruno. 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.

San Mateo County Superior Court — Hall of Justice

The San Mateo County Superior Court Hall of Justice at 400 County Center, Redwood City CA 94063 is the primary county venue for civil, criminal, family, probate, and small-claims matters. R&TC §19382 / §19385 refund suits, divorce-tax allocation, probate-tax matters, and county business-tax disputes proceed here.

San Mateo County Assessor & AAB

The San Mateo County Assessor at 555 County Center, Redwood City CA 94063 administers Prop 13 base-year values, Prop 19 parent-child transfers, supplemental assessments, and the property roll across San Bruno. The Assessment Appeals Board at the Clerk of the Board, 400 County Center, hears reassessment petitions under R&TC §1603-1611. San Mateo County uses the September 15 filing deadline for the regular roll.

San Mateo County Treasurer-Tax Collector

The San Mateo County Treasurer-Tax Collector at 555 County Center, Redwood City handles property-tax billing and collection across the county. San Bruno property-tax delinquencies on Crestmoor, Rollingwood, Pacific Heights, Mills Park, and central San Bruno parcels proceed through this office.

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 San Bruno 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 San Mateo 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 San Bruno — business license & TOT

The City of San Bruno administers the business-license tax under the San Bruno Municipal Code from City Hall at 567 El Camino Real, San Bruno CA 94066. San Bruno imposes a transient occupancy tax on hotels and short-term lodging in the SFO-airport-adjacent and Tanforan corridor. El Camino Real retailers, Tanforan-area operators, home-based contractors, and short-term rental owners all need current business licenses on file with the Finance Department.

San Mateo County Clerk-Recorder

The San Mateo County Assessor-County Clerk-Recorder at 555 County Center, Redwood City 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 San Bruno parcels route through this office.

Request a free consultation with a San Bruno 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 YouTube, Google, Alphabet, Walmart eCommerce, the National Archives at San Bruno, Skyline College, or one of the SFO-based airlines (United, Delta, American, Alaska, Southwest, JetBlue, Air Canada, Lufthansa, ANA, JAL, EVA, Singapore, Cathay Pacific, British Airways, SkyWest); if you work for the City of San Bruno or the Central County Fire Department; if you hold accounts at BDO Unibank, BPI, Metrobank, Landbank, PNB, Bank of China, ICBC, or CCB; if you own Crestmoor, Rollingwood, Pacific Heights, Mills Park, Lomita Park, Belle Aire, or Portola Highlands property; or if you received a 2010 PG&E Line 132 pipeline-disaster settlement payment — your most recent W-2, 1099, K-1, Schedule E, Schedule C, RSU and option statements, ESPP confirmations, §409A election forms, airline-carrier W-2 with state-allocation columns, settlement-administrator 1099 reports, 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 San Bruno and all of San Mateo County.

Frequently asked questions — San Bruno

Author & reviewer

Amir Boroumand, Esq.

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 San Bruno matters: YouTube and Alphabet RSU, ISO, AMT, ESPP §423, §409A nonqualified deferred compensation, and §415 SERP representation for the 901 Cherry Avenue executive and senior-employee workforce; Walmart eCommerce equity-comp and severance work for the 850 Cherry Avenue engineering team; SFO airline-crew 49 USC §40116(f) Pilots and Flight Attendants Tax Fairness sourcing and IRC §911 foreign-earned-income work for the United, Delta, American, Alaska, Southwest, JetBlue, Air Canada, Lufthansa, ANA, JAL, EVA, Singapore, Cathay Pacific, British Airways, and SkyWest workforce based at SFO; 2010 PG&E Line 132 pipeline-disaster settlement classification under IRC §104(a)(2), §139, §61, §1033, and §6511 for Crestmoor survivors and successors; National Archives at San Bruno federal-employee and 1099 contractor representation; FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing Compliance Procedure work for the San Bruno Filipino-American community (BDO Unibank, BPI, Metrobank, Landbank, PNB, UnionBank, Security Bank, RCBC) and Chinese-American community (Bank of China, ICBC, China Construction Bank, Agricultural Bank, China Merchants); Prop 8 decline-in-value appeals at the San Mateo County Assessment Appeals Board at 400 County Center Redwood City; Prop 13 base-year and Prop 19 parent-child transfer analysis at the San Mateo County Assessor at 555 County Center; FTB residency audits following moves to Austin, Seattle, Reno, Boise, and Coeur d'Alene; City of San Bruno municipal-employee CalPERS plus §457(b) plus §401(k) coordination; Skyline College adjunct §117(c), §127, and §403(b) work; BART San Bruno transit-fringe and cross-county wage-sourcing matters; City of San Bruno business-license and transient-occupancy tax matters at 567 El Camino Real; and U.S. Tax Court petitions designated to the San Francisco trial city.

Last Reviewed:

Parham Khorsandi, Esq.

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), federal Internal Revenue Code citations, the 49 USC §40116(f) Pilots and Flight Attendants Tax Fairness statute, the IRC §104(a)(2), §139, and §1033 disaster-settlement framework, named California and federal entities (FTB San Francisco at 121 Spear Street, CDTFA San Francisco, OTA, San Mateo County AAB at 400 County Center Redwood City, San Mateo County Assessor at 555 County Center, IRS San Mateo TAC at 977 South Claremont Street, NDCA San Francisco Division, U.S. Tax Court San Francisco, City of San Bruno at 567 El Camino Real, San Mateo County Superior Court Hall of Justice at 400 County Center), FBAR and Form 8938 framework citations (31 USC §5314, IRC §6038D, IRC §1297, 31 CFR §1010.350), Alphabet §409A and §415 nonqualified deferred compensation citations, Skyline College §117(c) and §403(b) citations, 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. YouTube and Alphabet RSU, ISO, ESPP, AMT, and §409A planning, Walmart eCommerce equity work, SFO airline-crew 49 USC §40116(f) sourcing, FBAR and Form 8938 cross-border compliance for Filipino-American and Chinese-American clients, 2010 PG&E Line 132 pipeline-disaster settlement classification, Prop 8 decline-in-value AAB appeals, FTB residency audits, City of San Bruno municipal-employee CalPERS / §457(b) coordination, and Skyline College adjunct §117(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.

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