FAQs

Ben-Cohen Law Firm represents individuals, business owners, executives, investors, fiduciaries, and professionals in civil and criminal tax controversies. We handle IRS audits, IRS Appeals, tax litigation, criminal tax investigations, voluntary disclosures, offshore reporting matters, collection disputes, and state tax controversies.

Pedram Ben-Cohen is a tax attorney and Certified Public Accountant who focuses exclusively on tax controversy matters. He represents taxpayers before the Internal Revenue Service, the Department of Justice, the California Franchise Tax Board, and federal courts.

Our office is located in Los Angeles, California. We represent clients throughout California and across the United States in federal tax matters.

Yes. A significant portion of our practice involves representing high-net-worth individuals, entrepreneurs, executives, investors, real estate owners, and closely held business owners facing complex tax disputes.

Do not ignore the notice or contact the IRS before understanding the issues involved. Early involvement by experienced tax counsel can significantly affect the outcome of an audit.

In most cases, yes. Once we are authorized to represent you, we can communicate directly with the IRS and manage the audit process.

We represent clients in correspondence audits, office audits, field audits, partnership examinations, employment tax audits, and examinations involving offshore accounts, cryptocurrency, and high-income taxpayers.

In some circumstances, yes. If the IRS believes there may have been fraud, willful noncompliance, or other criminal conduct, a civil audit can potentially be referred to IRS Criminal Investigation.

Common indicators include contact by IRS Special Agents, grand jury subpoenas, search warrants, requests for interviews, or inquiries directed toward friends, family members, employees, or business associates.

Revenue Agents conduct civil examinations. Special Agents are criminal investigators whose primary function is investigating potential violations of federal tax and financial crimes laws.

You should consult experienced criminal tax counsel before answering any questions. Statements made during an investigation can have significant legal consequences.

Tax evasion generally involves the willful attempt to evade or defeat taxes through affirmative acts. Whether criminal exposure exists depends on the specific facts and circumstances of each case.

In some cases, yes. Early intervention by experienced counsel may help limit exposure and achieve favorable outcomes before formal charges are brought.

You should consult a qualified tax attorney before making any contact with the IRS. Various compliance options may be available depending on your facts and circumstances.

An FBAR (Foreign Bank Account Report) is an annual filing required for certain U.S. persons with foreign financial accounts exceeding applicable reporting thresholds.

FBAR penalties can be substantial and may vary depending on whether the government alleges non-willful or willful conduct.

The Voluntary Disclosure Practice allows certain taxpayers with potential criminal tax exposure to come forward and resolve prior noncompliance before the government initiates an investigation.

Potentially. However, the appropriate approach depends on your facts and should be evaluated carefully before filing amended returns or making disclosures to the government.

The IRS Independent Office of Appeals is designed to resolve tax disputes without litigation. Appeals Officers operate independently from IRS Examination and Collection personnel.

Yes. We regularly represent taxpayers before IRS Appeals and seek to resolve disputes efficiently and favorably whenever possible.

Taxpayers often have administrative and judicial remedies available. The appropriate course depends on the specific facts and procedural posture of the case.

Yes. We represent taxpayers before the United States Tax Court and, when appropriate, in federal district courts and the United States Court of Federal Claims.

No. Most tax controversies are resolved through settlement negotiations, Appeals proceedings, or other pretrial resolutions.

Depending on your circumstances, options may include installment agreements, offers in compromise, currently not collectible status, penalty abatement, collection appeals, or litigation.

Yes. Under certain circumstances, the IRS may levy bank accounts and other assets after complying with applicable legal procedures.

Yes. The IRS has authority to issue wage levies in certain collection matters.

Although relatively uncommon, the IRS may seek to seize certain assets, including real property, in appropriate cases.

In some situations, penalties may be reduced or abated based upon reasonable cause or other available relief provisions.

Yes. We represent taxpayers in audits, appeals, collection matters, residency disputes, and litigation involving the California Franchise Tax Board.

Yes. Information obtained during an IRS examination is often shared with state taxing authorities.

A residency audit examines whether an individual is properly classified as a California resident for income tax purposes.

California’s ability to tax income after a move depends on numerous factors, including residency status, source of income, and applicable tax law.

The answer depends on the facts. While many audits are subject to a three-year limitations period, longer periods may apply in certain circumstances.

Generally, the statute of limitations does not begin to run until a return is filed.

In many cases, the IRS has ten years from assessment to collect a tax liability, although the collection period may be extended in certain circumstances.

FBAR matters involve separate statutory provisions and deadlines that differ from the Internal Revenue Code.

Tax controversies often involve complex procedural, evidentiary, and strategic considerations. Experienced representation can help protect your rights and improve the likelihood of a favorable resolution.

Many tax disputes involve both legal and accounting issues. As both a tax attorney and CPA, Pedram Ben-Cohen brings experience in both disciplines.

Generally, communications with an attorney seeking legal advice are protected by the attorney-client privilege, subject to applicable law.

For urgent matters involving audits, investigations, collection actions, subpoenas, or criminal tax issues, we can often begin evaluating a matter immediately.

Contact Ben-Cohen Law Firm through our website or by telephone to schedule a confidential consultation regarding your tax matter.