STATE & LOCAL TAX

State audits are a different animal. We handle them too.

State and local tax disputes are roughly a fifth of our practice. We represent businesses and individuals in Texas sales tax audits, California residency audits, and a wide range of state controversies across the country.

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WHAT WE DO

State tax is not federal tax with a different name.

The rules are different, the procedures are different, and the appeal rights are different. A Texas Comptroller sales tax audit, a California Franchise Tax Board residency audit, and a New York unincorporated business tax case have almost nothing in common — except that each one has to be handled inside its own deadlines.

We represent clients through state and local examinations, administrative appeals, redetermination hearings, and judicial review where the controversy survives administrative remedies.

Texas sales and use tax

Texas Comptroller audits are records-driven and unforgiving. Sampling methodology, taxability of mixed transactions, and exemption documentation determine the outcome. We represent retailers, restaurants, contractors, oil-and-gas service companies, and other businesses through the audit, the redetermination hearing, and the State Office of Administrative Hearings.

California residency audits

California’s residency rules turn on the closest-connections test and a long list of factual factors. We represent former Californians, part-year residents, and dual-residence individuals in FTB residency examinations and protests — including cases involving deferred compensation, equity events, and post-move income sourcing.

Matters we handle

  • Texas sales and use tax audits and refund claims
  • Texas franchise tax controversies and apportionment disputes
  • California residency and source-of-income audits (FTB)
  • California sales and use tax (CDTFA) audits
  • Multi-state nexus, apportionment, and combined-reporting issues
  • State income tax audits and protests in other jurisdictions
  • Sales tax voluntary disclosure agreements
  • Responsible-person assessments at the state level
  • State tax court and administrative hearing representation

Received a state tax notice?

Whether it’s a Texas Comptroller engagement letter or an FTB residency questionnaire — the earlier we are involved, the more we can do.

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