Tax Attorney in Solano County

The U.S. Tax Court holds San Francisco trial sessions at the Phillip Burton Federal Building, 450 Golden Gate Avenue, San Francisco CA 94102. A Solano County petitioner designates "San Francisco, California" as the place of trial on the petition under Tax Court Rule 140. Sacramento is also available and sometimes a better calendar fit, with sessions at the Robert T. Matsui U.S. Courthouse, 501 I Street, Sacramento. Petitioners may also designate Los Angeles if travel logistics make sense. The petition itself must reach the Tax Court within 90 days of the Notice of Deficiency date.

Under IRC §112, any month in which an enlisted member serves any portion in a designated combat zone is fully excluded from federal gross income for that member's military pay. For officers, the exclusion is capped at the highest enlisted pay plus hostile-fire and imminent-danger pay. Designated combat zones currently include the Afghanistan/Iraq/Syria theater, the Sinai (under presidential designation), parts of Yemen, and the Kosovo theater for legacy claims. Direct support areas like Qatar, Bahrain, and the UAE qualify when in support of combat-zone operations. The exclusion runs from the day you enter the zone through the date you depart, with hospitalization extensions if injured. DFAS reflects the exclusion on the W-2, but errors happen — we audit the W-2 against deployment orders and file amended returns when the exclusion was undercoded.

The Military Spouses Residency Relief Act (50 USC §4001) lets a military spouse retain a non-California state of residence for income-tax purposes if the spouse is in California solely to be with the servicemember under military orders. The Veterans Benefits and Transition Act of 2018 expanded MSRRA so a spouse may elect the servicemember's state of legal residence regardless of where the spouse previously lived. Practical effect: if your servicemember claims Texas, Florida, or Nevada as state of legal residence on the LES, you can claim the same and not file a California Form 540 on Solano County wages earned while present under orders. The FTB audits these claims under Cal. Rev. & Tax. Code §17014, looking at marriage timing, prior-state ties, and whether the move to California was tied to orders. We document each piece before claiming.

Several. Genentech and Roche affiliates withhold federal tax on RSU vests at the flat 22 percent supplemental rate, which routinely underwithholds employees whose marginal rate exceeds 37 percent federal plus 13.3 percent California. The first step is verifying the W-2 reflects the vest correctly — ADR cost basis errors are common with Roche-parent equity. Options include a streamlined IRS Installment Agreement under IRC §6159 for balances under $50,000, a Non-Streamlined IA above that with Form 433-F disclosure, a Partial Pay IA where Reasonable Collection Potential is below the full liability, or a parallel FTB plan on the California side. We model the cash-flow against future vest schedules so the plan does not default at the next vest.

Several options. First, the AMT credit under IRC §53 carries forward indefinitely and recovers in years when regular tax exceeds tentative minimum tax. Second, a Disqualifying Disposition in the same calendar year as exercise converts AMT preference treatment to regular ordinary income, often a smaller bill. Third, where the share price collapsed after exercise, the loss on sale generates a capital-loss carryforward that combines with the AMT credit over time. Fourth, payment of the AMT can be structured through an Installment Agreement under IRC §6159. Fifth, reasonable-cause penalty abatement is available where the AMT was unexpected and the underpayment was a good-faith estimate error. We model each path before recommending.

Severance pay is ordinary wage income and subject to federal income tax, FICA, Medicare, and California income tax plus SDI. Employers withhold federal tax at the 22 percent supplemental rate, which underwithholds workers in upper brackets. Accrued vacation paid out is also wages. If you received a lump-sum pension distribution at separation, Net Unrealized Appreciation under IRC §402(e) may apply to employer stock inside the plan, converting ordinary-income treatment to long-term capital gains on the appreciation. If you were under 59 1/2, the 10 percent early-distribution penalty under IRC §72(t) applies unless an exception fits — the separation-from-service at age 55 exception is common for refinery and brewery workers. We coordinate the sequence before a 60-day rollover deadline closes.

The City of Vallejo's 2008 Chapter 9 municipal bankruptcy — one of the largest in U.S. history at the time — restructured Other Post-Employment Benefits (OPEB) and modified some retiree health-coverage obligations while preserving CalPERS pensions intact. Tax treatment depends on what you actually received. Pension payments through CalPERS continue to be ordinary income on Form 1099-R. Lump-sum settlement payments related to OPEB restructuring may be treated as wages on a W-2 or as miscellaneous income on Form 1099-MISC depending on issuer characterization. Reduced future benefits do not generate a deductible loss. If you received a one-time payment during the restructuring window, we pull the issuing document and trace through to the right return position. The case-law and bankruptcy-plan documents matter for substantiation.

For W-2 employees, the federal home-office deduction was suspended for tax years 2018-2025 under the Tax Cuts and Jobs Act, so unreimbursed employee expenses are not deductible on Schedule A. California did not conform — the home-office deduction remains available for state purposes on Form 540 Schedule CA. For self-employed consultants on Schedule C, the federal home-office deduction continues under IRC §280A(c). The City of San Francisco gross-receipts and payroll-expense taxes can also surface for employers with SF nexus — payroll allocated to days worked physically in San Francisco. Ferry commuting days from Vallejo count as physical SF presence; remote days from a Glen Cove home office do not. Documentation of physical work locations is the foundation.

California uses the domicile test at Cal. Rev. & Tax. Code §17014 and FTB Publication 1031, weighing nine factors: physical-presence days, location of family, location of primary residence, driver's license, vehicle registration, voter registration, banking, professional licenses, and business or social ties. Retaining a Northgate, Browns Valley, or Green Valley home as a "second home" while claiming Nevada residency is the most common reason Solano departing-resident audits fail. The defense is a documented clean break at the time of the move: new driver's license, new voter registration, sale or lease of the California home, transfer of professional licenses, and a careful physical-presence log under the nine-month presumption rule. Travis AFB retirees often retain Solano property for proximity to David Grant Medical Center healthcare — that factor cuts against the move and needs to be addressed directly.

AB 5 codified the ABC test from Dynamex into Cal. Lab. Code §2775. To classify a worker as a 1099 contractor, the company must show (A) freedom from control and direction, (B) the work falls outside the company's usual course of business, and (C) the worker is engaged in an independent trade. Solano County construction subcontractors in the Fairfield-Vacaville growth corridor, refinery turnaround crews at Valero Benicia, brewery contract labor, and trucking through the Port of Benicia all draw scrutiny. A reclassification produces back UI, ETT, SDI, and PIT withholding for three years plus penalties under Cal. Unemp. Ins. Code §1126. The defense is exemption analysis, business-to-business documentation, and protest filings.

The IRS Fairfield Taxpayer Assistance Center is located at 1900 Lewis Brown Drive, Fairfield CA 94533 — the closest TAC to most Solano County residents, sitting near the Highway 12 / I-80 interchange. Appointments are required and made through apps.irs.gov/app/office-locator or by calling 844-545-5640. Sacramento and Oakland TACs are also options for residents on the eastern and southern edges of the county. For most resolution work, in-person visits are not required — we represent clients by Form 2848 PoA and route notices directly to counsel.

FTB suspension under Cal. Rev. & Tax. Code §23301 happens when an entity fails to pay the $800 minimum franchise tax, fails to file the annual return, or fails to file a Statement of Information with the California Secretary of State. A suspended entity loses the right to sue, defend a lawsuit, or contract in California courts. Contracts signed during suspension are voidable. To revive, file the missing returns, pay the tax plus penalties and interest under §19131 and §19132, and submit FTB Form 3557 (revivor request). The SOS Statement of Information must also be brought current. Once both agencies confirm compliance, the FTB issues a Certificate of Revivor.

A Notice of Federal Tax Lien recorded with the Solano County Assessor-Recorder clouds title until released, subordinated, discharged, or withdrawn. For refinance, the typical path is subordination under IRC §6325(d): Form 14134 (Application for Certificate of Subordination of Federal Tax Lien) shows the IRS that the refinance proceeds will pay down the tax debt or that subordination otherwise helps collection. If the underlying liability has been paid, request release on Form 668(Z). If you are on a streamlined IA under $25,000, lien withdrawal under Fresh Start (Form 12277) is available and clears title cleaner than release. The FTB State Tax Lien parallel under Cal. Gov. Code §7174 has its own release and subordination procedures.

No. The firm is headquartered at 1100 S. Robertson Boulevard in Los Angeles, and we represent clients across all 58 California counties. Solano County engagements run by phone, secure portal, and email; in-person meetings happen by appointment at the LA office for clients who prefer face-to-face. We appear at the FTB Sacramento and Oakland field offices, U.S. Tax Court San Francisco and Sacramento trial sessions, the IRS Fairfield TAC, and the Solano County Superior Court Hall of Justice in Fairfield as case calendaring requires. Travis AFB servicemembers deployed overseas continue to work with us by email and secure document exchange throughout the deployment.