
An IRS letter showed up in your mailbox, and your stomach has not settled since. You keep running the numbers in your head, wondering if this touches your savings, your house, or the business you spent years building. When the IRS or the California tax agencies propose more tax or a penalty, the real question is how to resolve it before it becomes final.
You need advice about what to do next.
Evan L. Smith began his career as a tax professional at a Big Eight accounting firm, so he reads an IRS file the way an accountant reads a balance sheet. Martindale-Hubbell has rated him AV Preeminent, its highest peer rating, every year since 1989.
Contact us and tell us what the IRS sent you. We will tell you plainly what it means and what happens next.
| 44+ Years Practicing Law | AV Preeminent Since 1989 | Founded on Values of Military Service – U.S. Army Veteran | State Bar of California Since 1981 |
A Murrieta tax attorney handles the full range of federal and California tax disputes facing residents and business owners, with a focus on defending against proposed tax and penalty assessments and resolving them in or out of court, including:
These matters move quickly, and getting ahead of the deadline on a notice is often what keeps a resolution possible before the government makes costly decisions for you.
Call for a Consultation (951) 525-1161
Murrieta’s median household income runs well above the national average, and many residents here own businesses or file complex returns, so a proposed assessment or penalty can carry real dollars. Once the IRS assesses a tax debt, a federal lien attaches to essentially everything
you own, including your home equity and property you acquire later (26 U.S.C. § 6321). If the debt goes unresolved, the IRS can move to a levy, seizing funds directly from your bank account or garnishing your wages.
Not every IRS letter means the same thing, and the deadline attached to it can be the difference between having options and having none. For example:
A CP2000 notice usually means the IRS found a mismatch between your return and what an employer or bank reported, and it gives you a window to respond before the balance is assessed. It is a proposed change, not a final bill, and you can dispute it. If you miss that window, the IRS’s proposed changes become final and the balance moves straight to collections.
A Notice of Deficiency, sometimes called a 90-day letter, starts a strict 90-day clock to petition the U.S. Tax Court before the IRS can assess the tax (26 U.S.C. § 6213). Miss that clock, and the tax gets assessed automatically, closing off the option to dispute it in Tax Court before paying.
A Final Notice of Intent to Levy gives 30 days before the IRS can take money directly from your bank account or paycheck. Requesting a Collection Due Process (CDP) hearing inside that 30-day window pauses the levy while your case is reviewed.
Reading the notice correctly, and responding inside the deadline it sets, matters significantly in a tax dispute.
Yes. A CP2000 or a notice of deficiency proposes changes you can contest, and many penalties can be reduced or removed when you show reasonable cause. Acting inside the deadline keeps your options open.
Often, yes. The IRS Independent Office of Appeals reviews disputes separately from the office that proposed the change, and options like an offer in compromise or a payment plan resolve many matters out of court.
Cost usually depends on how complex your matter is and how many years are involved. Before you hire an attorney, understand whether the lawyer charges by the hour or sets a flat fee. It is also worth understanding the tax, penalties, and interest you could face if the dispute is unsuccessful.
A single-issue matter may be resolved in a few months. A field audit, an unfiled-returns matter, or a dispute that reaches Tax Court can take a year or more. The timeline may move faster once an attorney is handling communication with the IRS instead of you.
A CPA can prepare returns and represent you in many routine matters, but only an attorney can represent you in U.S. Tax Court, work under attorney-client privilege, and take over communication with IRS collections once a case becomes adversarial. Many clients use both, with the attorney directing strategy.
Ignoring a notice does not stop the deadline attached to it from running. Once that window closes, the IRS gains more leverage. A lien can attach to property you own now or acquire later, and a levy can reach your bank accounts or paycheck directly.
We review the notice or lien you received, confirm exactly what deadline you are working against, and outline the realistic options for your situation, whether that is a response to the notice, an offer in compromise, or a Tax Court petition. You do not have to translate IRS language on your own before that conversation happens.
If your notice has a deadline printed on it, that deadline does not pause while you decide what to do next. Contact Evan L. Smith, Attorney at Law, and tell us what the IRS sent you. We will give you a plain answer about what it means and what your realistic options are, starting with a consultation.
Evan L. Smith blends extensive courtroom experience with a pragmatic approach that keeps
client informed, empowered and positioned for success.
Call for a Consultation (951) 525-1161
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41877 Enterprise Circle N Suite 200
Temecula, CA 92590 Meetings by Appointment
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