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Tax Attorney in Yolo County
Federal IRS and California state tax representation for Yolo County taxpayers — from UC Davis faculty, postdoctoral fellows, and CalPERS-covered staff in Davis, to UC Davis Health physicians billing on a 1099 through the Sacramento Medical Center, to Woodland agricultural growers running Schedule F operations on tomatoes, rice, almonds, and wine grapes, to West Sacramento port workers, Raley Field staff, and the Bay Area / Sacramento commuter overflow, and the biotech founders spinning out of UC Davis labs claiming Qualified Small Business Stock under IRC §1202. Our California Bar-admitted attorneys appear directly before the IRS, the Franchise Tax Board, CDTFA, EDD, the California Office of Tax Appeals, and the U.S. Tax Court, with Sacramento trial sessions held at the Robert T. Matsui U.S. Courthouse on I Street.
By Parham Khorsandi, Esq. — California Bar #266658. Admitted to practice before the United States Tax Court. Last Reviewed: .
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Service area: 4 incorporated cities in Yolo County · statewide CA representation Free consultation: (800) 883-8301 Last Reviewed:
Yolo County taxpayers facing IRS or FTB collection
If you live in Davis, Woodland, West Sacramento, or Winters, you sit in a tax environment shaped by three forces that rarely meet anywhere else in California. UC Davis anchors the county with thousands of tenured faculty, lecturers, research staff, postdoctoral fellows, and CalPERS-covered employees, plus the UC Davis Health system operating its main medical center across the river in Sacramento with physicians who often hold both W-2 academic salary and 1099 supplemental clinical income. Yolo County agriculture produces a meaningful share of the state's processing tomatoes, along with rice in the Knights Landing and Dunnigan areas, almonds and wine grapes around Winters, and seed crops across the Capay Valley — all Schedule F operations with USDA program payments, federal crop insurance, AB 5 farm-labor rules, and depreciation timing that drift in and out of the IRS exam queue. West Sacramento adds Port of West Sacramento commerce, Raley Field (Sutter Health Park) hospitality and seasonal staff, the riverfront development corridor, and a daily commuter base flowing into the State Capitol. If you have an IRS or FTB balance, an audit notice, or a wage levy from the EDD, this page walks through what Yolo County representation looks like.
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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 Yolo County tax matters require a California-licensed firm
Yolo County occupies the agricultural heart of the lower Sacramento Valley, with UC Davis as the academic and economic anchor and the City of Sacramento immediately across the river. The University of California, Davis — founded in 1908 as the University Farm and now one of the ten UC campuses — employs thousands across academic, research, medical, and administrative tracks. The UC Davis Medical Center, which sits inside Sacramento County on Stockton Boulevard, runs the only Level I trauma center for inland Northern California and an NCI-designated cancer center serving the region; many of its physicians, surgeons, and academic clinicians live in Davis and bill supplemental clinical work on 1099. Yolo County's agricultural sector, anchored in the Sacramento Valley alluvial soils west of the river, supplies a majority share of California's processing tomatoes — the raw material for the bulk of canned tomato product consumed in the United States — plus rice fields in the Knights Landing and Dunnigan corridor, almond and wine-grape acreage around Winters and the Capay Valley, and seed and specialty-crop operations across the unincorporated belt. The Port of West Sacramento, the Tower Bridge corridor, and Sutter Health Park (Raley Field) round out the city profile.
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 Yolo County 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, our Tax Court bar admission has nationwide reach. A Yolo County petitioner designating the U.S. Tax Court's Sacramento trial city under Tax Court Rule 140 hears the case at the Robert T. Matsui U.S. Courthouse, 501 I Street, Sacramento. Federal refund suits and criminal-tax matters for Yolo County residents proceed in the U.S. District Court for the Eastern District of California, headquartered at the same Matsui Courthouse.
The pages that follow lay out the practice areas, the venue map, settlement ranges from prior cases, the seven-step engagement process, and the FAQs answering what Yolo County taxpayers actually ask.
Your tax rights as a Yolo County taxpayer
Federal taxpayer rights are codified across the Internal Revenue Code and summarized in IRS Publication 1. California layers its own rights through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel provisions for CDTFA and EDD. UC Davis academic appointees draw on the UC Retirement Plan and CalPERS provisions; agricultural filers add Schedule F, USDA program rules, federal crop insurance, and AB 5 farm-labor classification questions; UC Davis biotech founders working with QSBS under IRC §1202 layer §83(b) and rollover §1045 elections onto the regular regime.
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 remainder of the matter.
Right to representation (California)
FTB Form 3520-PIT or 3520-BE appoints counsel before the Franchise Tax Board. CDTFA Form 392 covers sales-tax matters; EDD DE 48 covers payroll and AB 5 audits common in Yolo agriculture. Once on file, every notice routes to your attorney.
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.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Yolo County petitioners can designate Sacramento as the place of trial, with sessions at the Robert T. Matsui U.S. Courthouse, or San Francisco where calendar timing fits.
Right to a fellowship §117 review
Under IRC §117, qualified scholarship and fellowship amounts used for tuition and required fees are excluded from federal gross income for degree candidates. Amounts paid for room, board, or required teaching/research services are taxable. UC Davis doctoral candidates and postdoctoral fellows funded through NIH, NSF, or USDA training grants need the §117 line walked carefully against the 1098-T and any 1099 stipend report.
Right to challenge MHSA surtax allocation
Under Cal. Rev. & Tax. Code §17043, the Mental Health Services Act adds a 1 percent surtax on taxable income above $1 million. UC Davis Health surgical and procedural physicians billing high-volume clinical 1099 work, UC Davis startup founders with a QSBS partial exclusion year, and Yolo agricultural operators selling acreage often cross the threshold. Source-allocation arguments matter where part of the income relates to services performed outside California.
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 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
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.
How Victory Tax Lawyers helps Yolo County 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 financial under Cal. Rev. & Tax. Code §19443. The two reviews run on different Reasonable Collection Potential math. California weighs Yolo County real-estate equity — especially the East Davis and South Davis residential market driven by UC faculty demand, Woodland's older single-family inventory, and the West Sacramento riverfront corridor — tougher than the IRS does. For agricultural operators, farmland equity, equipment, and stored-crop inventory drive RCP up sharply on both sides.
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. Yolo agricultural operators often need an IA structured around the post-harvest cash cycle — tomato gross-receipts arrive late summer through fall, almond and wine-grape receipts run on different windows — so the monthly payment matches actual operating cash, not a calendar average.
Lien release and withdrawal
A federal NFTL under IRC §6321 and FTB State Tax Liens under Cal. Gov. Code §7170 attach to Yolo County real property and are recorded with the Yolo County Clerk-Recorder in Woodland. We pursue release after payment, certificate of discharge, subordination for refinance, and lien withdrawal under Fresh Start for IAs under $25,000. Agricultural-land liens that interfere with USDA Farm Service Agency loan packages need careful subordination sequencing.
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. UC Davis payroll handles wage garnishments through the UCPath system; we coordinate releases directly with UC Davis payroll services and the affected payroll cycle.
Audit and exam defense
IRS correspondence, office, and field audits with Sacramento-region examiners. FTB residency audits under Cal. Rev. & Tax. Code §17014 on UC Davis visiting faculty and post-doctoral fellows who maintain home-state ties. CDTFA sales-tax audits on Davis and Woodland restaurants, automotive dealers along the Highway 113 corridor, and cannabis operators in unincorporated Yolo. EDD AB 5 audits on agricultural labor crews, custom-farming contractors, and seasonal harvest help for tomato, rice, and wine-grape operations.
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 Yolo filers affected by the 2020 LNU Lightning Complex which burned through western Yolo and the Capay Valley, the 2017 atmospheric-river flooding along the Cache Creek and Yolo Bypass, PG&E Public Safety Power Shutoffs, and prolonged smoke events that disrupted UC Davis academic and agricultural operations.
Twelve tax issues we handle for Yolo County clients
Federal and California state practice areas framed for the matters that walk through the door from Davis, Woodland, West Sacramento, and Winters.
UC Davis CalPERS and UCRP retirement issues
UC Davis academic and staff appointees participate in the University of California Retirement Plan or in CalPERS, depending on hire date and classification. Lump-sum cashouts on separation, Capital Accumulation Provision (CAP) balances, and pre-1990 service buyouts produce 1099-R income often in unexpected brackets. We trace UCRP and CalPERS reporting against the 1040 and Schedule CA, and apply early-distribution exceptions under IRC §72(t) where they fit.
Fellowship and scholarship under IRC §117
UC Davis doctoral candidates and postdoctoral fellows working under NIH F31, F32, T32, NSF GRFP, USDA NIFA, and similar training awards face partial taxability under IRC §117. Amounts applied to tuition and required fees exclude; amounts paid for living costs or required services are taxable. We reconcile the 1098-T, any Form W-2, and any 1099 stipend reporting against the underlying award agreement.
UC Davis Health physician 1099 supplemental income
UC Davis Health physicians often hold a base UC academic appointment plus 1099 supplemental clinical, locum, telehealth, or expert-witness work. Quarterly estimated payments under IRC §6654 are required; underpayment penalties hit fast. Schedule C, self-employment tax, qualified-business-income deduction under IRC §199A (subject to specified-service-trade-or-business limits), and a solo 401(k) all interact.
Schedule F farm operations and USDA payments
Yolo tomato, rice, almond, and wine-grape operations file Schedule F with material participation, depreciation under IRC §179 and bonus depreciation, USDA program payments treated as ordinary income, federal crop insurance under IRC §451(f) with the one-year deferral election, and income averaging under IRC §1301. Audits focus on the activity-for-profit test under IRC §183 and on the line between trade-or-business expense and personal-use cost on dual-purpose acreage.
QSBS §1202 for UC Davis biotech spinouts
Founders of UC Davis lab-spinout biotech, agtech, and food-science startups holding Qualified Small Business Stock under IRC §1202 may exclude up to $10 million or 10x basis on sale after a five-year holding period. The CARES Act and recent expansions modified the exclusion percentage for stock acquired in different windows. We document acquisition date, original issuance, active-business test, gross-asset test under $50M, and §1045 rollover when reinvested.
AB 5 farm-labor classification
Yolo agricultural operations relying on custom harvesters, custom planters, mechanical-pruning crews, and seasonal field labor classified as 1099 face EDD AB 5 audits under the Dynamex ABC test, codified at Cal. Lab. Code §2775. Custom-farming and bona-fide independent agricultural businesses have a fact-specific path through prong B; we build the file with H-2A documentation, custom-rate contracts, and the equipment-and-skill independence record.
FTB residency audits on visiting faculty
UC Davis visiting professors, sabbatical hosts, and fellows arriving from out-of-state institutions for one- or two-year appointments often trip the nine-factor domicile test under Cal. Rev. & Tax. Code §17014 if they retain a home, voter registration, or family ties in their prior state. The safe-harbor 546-day rule under §17014(d) helps some; for others, a clean part-year resident filing is the answer. We document each piece against FTB Publication 1031.
West Sacramento commuter wage allocation
West Sacramento residents working at the Capitol, state agencies along the J Street corridor, downtown Sacramento law firms, and Bay Area tech companies on hybrid schedules face wage-allocation, Schedule C, and home-office-deduction questions. The Sacramento city limit runs along the Sacramento River, and the Tower Bridge crossing is the daily seam. Days worked physically across the river versus at a West Sacramento home office matter for state nonresident-spouse and city-tax purposes.
Trust Fund Recovery Penalty
Under IRC §6672, the IRS reaches owners of Yolo County 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 Davis and Woodland restaurants, West Sacramento construction subcontractors, and seasonal-labor farm operators where 941 deposits slipped during a tight quarter.
CDTFA sales-tax audits
Cash-intensive Davis restaurants near the UC campus and downtown G Street, Woodland Main Street operators, West Sacramento waterfront restaurants near Raley Field, and Winters wineries with tasting-room sales draw CDTFA mark-up audits. Agricultural-supply dealers selling resale-exempt versus retail-taxable items need the resale-certificate file in order. We push back on test-period methodology before it scales across the audit period.
USDA program clawbacks and Section 1245 recapture
USDA Farm Service Agency program payments, ARC/PLC, and Conservation Reserve Program rents are ordinary income. Sale of farm equipment depreciated under §179 triggers Section 1245 ordinary-income recapture up to prior depreciation. We coordinate the recapture math with installment-sale planning under IRC §453 and like-kind exchange of farmland under IRC §1031 (real property only post-2017).
U.S. Tax Court petitions
A 90-day petition in response to a Notice of Deficiency, designating Sacramento or San Francisco as the place of trial. Sacramento sessions are held at the Robert T. Matsui U.S. Courthouse, 501 I Street; the Eastern District of California sits in the same building for refund and criminal-tax matters.
Nine common causes of tax debt in Yolo County
1. UC Davis physician 1099 underpayment
A UC Davis Health surgeon takes on locum coverage at a rural critical-access hospital and earns six-figure 1099 income. Quarterly estimates were never set, federal and California marginal rates compound, and the April balance triggers an underpayment penalty under IRC §6654 plus an FTB parallel.
2. Fellowship stipend misclassified
A UC Davis postdoc receives an NIH NRSA fellowship reported on a courtesy letter instead of W-2 or 1099. The fellow files without recognizing the taxable portion under IRC §117. A CP2000 letter arrives two years later proposing tax on the full amount.
3. Bad tomato or rice crop year
A Yolo grower hits a drought year, a smoke-tainted wine-grape vintage, or a Russet Nematode tomato loss that wipes out the operating margin. Federal crop insurance pays, but the deferral election was not made, and an unexpected surge in gross receipts hits the prior plan's IA capacity. The next year's estimates lag behind.
4. QSBS exclusion misapplied
A UC Davis biotech founder sells founder stock after five years and applies the §1202 100 percent exclusion. The IRS questions whether the C-corporation qualified as an active business under the 80-percent test, or whether gross assets crossed $50M before issuance. A six- or seven-figure proposed adjustment lands.
5. Small-business payroll lapses
A Davis restaurant near the UC campus, a Woodland contractor, or a West Sacramento riverfront retailer stops depositing Form 941 trust funds during a slow quarter. The IRS asserts TFRP under IRC §6672 against owners personally; EDD asserts the state side under Cal. Unemp. Ins. Code §1735.
6. FTB residency audit on visiting faculty
A visiting professor arrives at UC Davis for a one-year sabbatical from a Texas or Florida university, keeps a home there, and files California part-year. The FTB asserts full-year residency under the nine-factor domicile test, citing the academic year duration, in-state checking account, and DMV registration.
7. AB 5 reclassification of farm labor
A Yolo tomato or wine-grape operator paid a custom-harvest crew as 1099 contractors. EDD reclassifies them as employees under the ABC test, assesses three years of UI, ETT, SDI, and PIT withholding, and adds penalties under Cal. Unemp. Ins. Code §1126.
8. ERC clawback exposure
Employee Retention Credit claims filed by promoter mills for Yolo County restaurants, Davis dental practices, Woodland medical offices, and West Sacramento logistics firms are being clawed back through CP207 and CP207L letters.
9. Wildfire, PSPS, and flood gaps
Filers affected by the 2020 LNU Lightning Complex which crossed into western Yolo and the Capay Valley, atmospheric-river flooding along the Cache Creek and Yolo Bypass, recurring PG&E Public Safety Power Shutoffs in unincorporated Yolo, and prolonged smoke events disrupting harvest and UC Davis operations missed deadlines. Disaster-zone extensions help during the active period, but penalty stacks accumulate once the window lapses.
Who is on the hook: eight Yolo County 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 post-divorce — subject to Innocent Spouse Relief under IRC §6015 and Cal. Rev. & Tax. Code §18533.
Academic divorces and tax allocation
The Yolo County Superior Court Family Law Division at 1000 Main Street in Woodland handles county dissolutions, including UC Davis dual-faculty divorces with UCRP and CalPERS pension division, lab-equity QSBS division, and Section 83(b) restricted-stock characterization. Allocation of joint federal liability, deferred compensation under QDROs, and academic-year sabbatical income matter. We coordinate with family-law counsel.
Responsible persons for payroll
TFRP under IRC §6672 reaches anyone with check-signing authority who willfully failed to pay over withheld taxes. The California parallel sits at Cal. Unemp. Ins. Code §1735 for EDD payroll personal liability. Common for Yolo agricultural cooperatives and partnership operators where the bookkeeper, general partner, and farm manager all share check authority.
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. Winters wineries with direct-to-consumer shipping, Davis tasting-room operators, and West Sacramento waterfront retailers should keep officer rosters and signature authority current.
FTB suspended-entity exposure
A Yolo County LLC suspended by FTB under Cal. Rev. & Tax. Code §23301 loses its right to contract or defend in California courts. Officers signing on behalf may incur personal exposure. Farm LLCs holding tomato or rice ground that drift past the $800 minimum franchise tax for a year or two are routine candidates.
Transferee liability
IRC §6901 reaches transferees where the transfer rendered the transferor insolvent and tax debt remains. Common with Prop 19 parent-child transfers of Yolo farmland and Davis residential real property, agricultural-LLC restructurings, and intra-family gifts of tomato and rice acreage near Woodland.
Successor business liability
Asset purchases continuing a seller's Yolo County operation can carry CDTFA successor liability under Cal. Rev. & Tax. Code §6811-6814 and EDD successor liability under Cal. Unemp. Ins. Code §1731. Buyers protect with clearance letters — routine for Davis restaurant transitions and Winters tasting-room sales.
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, with personal liability under 31 USC §3713(b) for premature distributions. Yolo County Superior Court probate jurisdiction at the Woodland courthouse governs the priority of state-tax claims, especially where farmland is the principal estate asset.
What resolution can look like in Yolo 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. 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 after a poor harvest year, an UC Davis sabbatical cycle, or a startup founder transition.
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 LNU Lightning Complex smoke and evacuation, Cache Creek and Yolo Bypass flooding, PSPS outages, serious illness, and preparer reliance. FTB waivers under §19131 and §19132 follow parallel principles.
Liens and levies released
A federal NFTL recorded with the Yolo 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 Yolo County tax matter
A Yolo County tax matter rarely sits in a single forum. A UC Davis Health physician audit on Schedule C 1099 deductions triggers a parallel California adjustment within four years through the federal-state information-exchange agreement. An EDD AB 5 audit on a Yolo tomato or wine-grape custom-harvest crew often runs alongside an IRS Form 4180 interview for Trust Fund Recovery. An FTB residency audit on a visiting professor returning to Texas or Florida usually pulls in property records from the Yolo County Assessor at 625 Court Street in Woodland. A QSBS-§1202 exclusion claim on UC Davis startup founder stock can draw both an IRS gross-asset audit and an FTB conformity question on California's partial non-conformity to §1202. 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 Sacramento or San Francisco place of trial, an Offer in Compromise — 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.
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, or Tax Court petition with the FTB, CDTFA, or EDD parallel strategy where applicable.
6
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.
7
Compliance close-out
Post-resolution monitoring: quarterly estimates, return filings, 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 — relevant for UC Davis faculty on extended international sabbatical.
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. That is 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 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.
Yolo County venue: federal and state tax forums
A Yolo County 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 county.
U.S. Tax Court — Sacramento trial sessions
The United States Tax Court holds Sacramento trial sessions at the Robert T. Matsui U.S. Courthouse, 501 I Street, Sacramento CA 95814. A Yolo County petitioner designates "Sacramento, California" as the place of trial on the petition under Tax Court Rule 140. San Francisco is also a workable designation given the firm's statewide footprint.
IRS Sacramento Taxpayer Assistance Center
The IRS operates a TAC at 4330 Watt Avenue, Sacramento CA 95821 — the closest TAC to most Yolo County residents, a short drive across the river from West Sacramento or down I-80 from Davis and Woodland. Appointments through apps.irs.gov/app/office-locator or 844-545-5640.
U.S. District Court (Eastern District of CA)
Federal refund suits and criminal-tax cases proceed in the U.S. District Court for the Eastern District of California, headquartered at the Robert T. Matsui U.S. Courthouse, 501 I Street, Sacramento CA 95814. Appellate review goes to the Ninth Circuit in San Francisco.
Yolo County Superior Court
State-tax civil collection actions, probate-tax matters, and family-law dissolutions proceed at the Yolo County Superior Court main courthouse, 1000 Main Street, Woodland CA 95695. The Davis branch handles certain limited-jurisdiction matters; civil, probate, and family-law calendars are anchored at the Woodland courthouse.
Yolo County Treasurer-Tax Collector
The Yolo County Treasurer-Tax Collector handles property-tax billing and collection at 625 Court Street, Room 102, Woodland CA 95695. Property-tax delinquencies on Davis residential parcels, Woodland inventory, West Sacramento riverfront property, and agricultural land across the unincorporated belt proceed through this office.
Yolo County Assessor
The Yolo County Assessor at 625 Court Street, Room 102, Woodland CA 95695 administers property valuation under Prop 13 / Prop 19, including the Williamson Act agricultural-preserve assessment for qualifying Yolo farmland. The Clerk-Recorder records federal NFTLs and FTB State Tax Liens against Yolo County real property.
California FTB Sacramento field office
The California Franchise Tax Board Sacramento field office serves Yolo County. We appear there on residency audits, Notice of Action protests, and FTB compromise filings under Cal. Rev. & Tax. Code §19443.
Cities & service area
Yolo County contains four incorporated cities: Davis, Woodland (county seat), West Sacramento, and Winters. Unincorporated areas include Capay, Esparto, Brooks, Knights Landing, Dunnigan, Madison, Yolo, Zamora, and the Cache Creek / Capay Valley corridor. We represent clients across all of them.
Request a free consultation with a Yolo County 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 are a UC Davis faculty or staff member, a UC Davis Health physician with 1099 work, a Yolo farm operator, or a biotech founder holding QSBS — your most recent paystub or W-2, fellowship award letter, Schedule F prior-year return, or §1202 grant documents. 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 all four cities of Yolo County.
Frequently asked questions — Yolo County
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 covers federal and California tax controversy across the state, including Yolo County matters: UC Davis faculty and staff CalPERS and UCRP retirement planning, postdoctoral fellowship and §117 stipend treatment, UC Davis Health physician 1099 supplemental clinical work, agricultural Schedule F operations on tomatoes, rice, almonds, and wine grapes, USDA program payment and crop-insurance deferral elections, AB 5 farm-labor classification audits, QSBS §1202 exclusion analysis for UC Davis biotech and agtech spinouts, FTB residency audits on visiting faculty, CDTFA sales-tax audits on Davis and Woodland restaurants and Winters wineries, West Sacramento commuter wage-allocation matters, and U.S. Tax Court petitions designated to the Sacramento trial city.
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, 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. Academic and research matters — UCRP / CalPERS retirement, IRC §117 fellowship taxation, UC Davis Health 1099 supplemental income, and QSBS §1202 founder-stock analysis — require appointment letters, award agreements, grant documents, and corporate formation records. Agricultural matters — Schedule F, USDA program payments, federal crop insurance deferral under §451(f), income averaging under §1301, and AB 5 farm-labor classification — require operating records, custom-contract files, and acreage 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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