IRS Tax Audit Representation

Disclaimer: The information below is provided for general educational purposes only and does not constitute legal or tax advice.

Tax Audit Representation

Trusted Tax Counsel with CPA Precision and Legal Insight

Zaher Fallahi, Attorney at Law, CPA, provides integrated legal and tax representation before federal and state taxing authorities. Combining the analytical discipline of a Certified Public Accountant with the strategic perspective of a seasoned attorney, Mr. Fallahi delivers comprehensive, results-driven representation in complex tax audits, offshore compliance, and tax resolution matters.

Prior to establishing his own firm in 1992, Mr. Fallahi worked with a nationwide professional firm and a major government agency, gaining invaluable experience in tax, regulatory, and financial systems. Since founding his CPA firm, he has collaborated closely with a mid-size law firm, providing a rare blend of legal and accounting expertise. This dual perspective allows him to handle each client’s matter with depth, accuracy, and strategic foresight — integrating legal advocacy with technical tax analysis at every stage.

For over three decades, Mr. Fallahi has represented individuals, businesses, estates, and fiduciaries before the Internal Revenue Service (IRS), California Franchise Tax Board (FTB), Employment Development Department (EDD), and the California Department of Tax and Fee Administration (CDTFA), formerly the State Board of Equalization. Our firm provides complete representation throughout the administrative process — from initial audit inquiries and examination conferences to appeals, settlements, and coordination with litigation counsel before the U.S. Tax Court or state tax tribunals.

We prepare detailed written responses, evidentiary submissions, and reasonable cause arguments to defend our clients’ positions with precision and professionalism. Our objective is to resolve tax controversies efficiently and favorably while protecting taxpayers’ procedural rights and minimizing exposure to penalties and liabilities. Drawing upon decades of experience in both federal and state tax controversies, our firm provides strategic, well-reasoned, and effective representation in even the most challenging cases.

Offshore and International Tax Compliance

Over time, our practice has expanded to include complex offshore and international tax compliance matters. We have successfully assisted numerous clients in rectifying prior noncompliance involving foreign income, accounts, and asset reporting. Our representation includes participation in:

• IRS Voluntary Disclosure Program (VDP)
• Streamlined Filing Compliance Procedures (SFCP), including:
  • Streamlined Foreign Offshore Procedures (for U.S. taxpayers residing abroad)
  • Streamlined Domestic Offshore Procedures (for U.S. residents)
• Delinquent FBAR Submission Procedures
• Delinquent International Information Return Submission Procedures, including Forms 5471, 8865, 3520, and 3520-A

These programs — designed for taxpayers whose non-compliance was non-willful and who are not under current IRS examination or criminal investigation — provide structured and protective pathways to full compliance, often with reduced or eliminated penalties. When executed properly, they enable taxpayers to come into compliance confidently and lawfully under U.S. tax procedures.

Tax Collection and Resolution Matters

In addition to audit and compliance cases, our firm represents clients in federal and state tax collection and resolution proceedings, including:

• Offers-in-Compromise (OIC)
• Installment Agreements
• Penalty Abatement Requests
• Innocent Spouse Relief
• Audit Reconsiderations and Appeals
• Negotiations with IRS and FTB Revenue Officers

Each engagement begins with a detailed analysis of the facts, supporting documentation, and governing law. We prepare comprehensive financial disclosures, legal memoranda, and reasonable-cause statements tailored to each client’s situation. Our extensive experience in working directly with revenue and appeals officers allows us to achieve fair, practical, and favorable outcomes for clients facing complex tax challenges.

Matters involving tax preparation, prior-year returns, or compliance restoration are handled through our affiliated Zaher Fallahi CPA, ensuring seamless coordination between legal representation and accounting support.

We can help you with the following:
✅ Audit Tax Representaion Nationwide, Foreign Accounts, Anti-Money Laundering (AML) Compliance
✅ Tax Resolution and Tax Offer-in-Compromise Services
✅ Cryptocurrency Tax, Crypto Fraud and Stolen Crypto Tax Help
✅ Ponzi Scheme Tax Relief & Loss Deduction Tax Help
✅ Foreign Gift & Inheritance, AML Compliance
✅ Offshore Accounts and Streamlined Procedures Services
✅ Office of Foreign Assets Control (OFAC) Iran OFAC License, AML Compliance

Contact Us for a Confidential Consultation:
📞 Toll-Free: 1-877-687-7558
📞 Los Angeles: (310) 719-1040
📞 Orange County: (714) 546-4272
📧 Email: taxattorney@zfcpa.com

Recognitions:

TOP Tax Attorney Ranked by Coast Magazine
Rated 10 of 10 by Avvo

Harvard Law School–Executive Programs in Negotiation & Leadership
Massachusetts Institute of Technology (MIT)–Executive Certificate in Blockchain Technologies: Basis of Cryptocurrency