
Tax problems can place enormous strain on your finances and peace of mind. When the IRS or a California tax agency proposes additional tax or penalties, the way you respond can shape your financial future. A tax attorney can help you dispute a proposed assessment, protect your assets, and work toward resolving the problem, whether that happens through negotiation with the agency or, when needed, in court.
Serious tax disputes can threaten your financial stability if they are not handled correctly. By working with Evan L. Smith, Attorney at Law, you gain access to a Temecula tax attorney who defends taxpayers against proposed tax and penalty assessments and understands the complexities of federal and state tax controversies.
With decades of experience and a background as a former accountant for a Big Eight public accounting firm, Mr. Smith is skilled in reviewing financial records, evaluating potential liabilities, and developing strategies to resolve tax disputes. He provides clear, reliable guidance so you can protect your assets and work toward a manageable resolution.
A proposed assessment is the government’s claim that you owe more than you paid. The Riverside area is home to nearly 21,000 businesses and contributes to a $104 billion gross regional product, and both individuals and companies here can face proposed tax or penalty adjustments from the IRS or California tax agencies.
The dollars at stake are significant. In fiscal year 2024, the IRS assessed about $84 billion in civil penalties on taxpayers nationwide. A proposed change often arrives as a notice, such as a statutory notice of deficiency, that gives you a limited time to respond before the amount becomes final. When a tax bill goes unresolved, the IRS may issue a federal tax lien, placing the government’s legal claim on personal or business assets.
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Even when you file in good faith, you can receive a notice proposing more tax than you reported. These proposed changes can come from a mismatch with third-party records, a disallowed deduction, or a question about income. You usually have a set period to respond, and how you answer can decide whether the amount is reduced, resolved, or made final.
Penalties are a common part of these disputes. The IRS can add penalties for late filing, late payment, or accuracy, and those amounts can grow quickly. Many penalties can be challenged or reduced when you can show reasonable cause or an error in the government’s position. Back taxes that go unresolved can also lead to liens and other collection steps.
If the IRS or a state agency has proposed additional tax or penalties, the decisions you make next can have a direct effect on your finances. A temecula valley tax attorney can review the notice, test whether the government’s position is correct, and respond within the deadline so you keep your options open.
Many disputes are resolved without a courtroom. The IRS Independent Office of Appeals reviews disagreements separately from the office that proposed the change, and an attorney can also pursue options such as an offer in compromise, a penalty reduction, or a payment plan. When a fair result is not possible out of court, your attorney can petition the U.S. Tax Court, which lets you dispute a proposed assessment before paying it. California tax disputes follow a parallel administrative path, where an attorney can handle appeals before state tax authorities such as the Franchise Tax Board.
It is the government’s formal claim that you owe more tax than you reported, often sent as a notice of proposed changes or a statutory notice of deficiency. You usually have a limited time to respond before the amount becomes final.
You can ask the IRS to remove or reduce a penalty by showing reasonable cause or an error in its position, and some penalties qualify for first-time relief. An attorney can prepare the request and gather the supporting facts.
Yes. Most disputes are settled with the IRS Independent Office of Appeals or through options like an offer in compromise, a penalty reduction, or a payment plan.
Yes. If you receive a statutory notice of deficiency, you can petition the U.S. Tax Court to dispute the proposed amount before paying it. Strict deadlines apply, so act quickly.
Not always. If you petition the U.S. Tax Court after a notice of deficiency, you can dispute the amount before paying. Other options require paying first and then asking for a refund.
Generally 90 days from the date on the notice, or 150 days if you are outside the United States. The deadline is strict and usually cannot be extended.
The proposed amount can become final, and the IRS can begin collection, including liens and levies. Responding on time keeps your options open.
An attorney can review the notice, challenge the government’s position, negotiate a resolution, and represent you in court if a fair outcome is not reached out of court.
Facing the IRS or a state tax agency without legal representation can be a costly mistake. Whether you have received a notice proposing more tax, a penalty you believe is wrong, or another tax dispute, you need representation from a firm that can protect you from serious civil liabilities.
Evan L. Smith, Attorney at Law, brings decades of experience defending taxpayers in and out of court. We can speak to the government on your behalf and negotiate favorable terms for resolving the issue. At all times, we prioritize the interests of our clients and provide honest and ethical representation. Contact our office today to schedule your 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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