Diego Alvarez Miranda Ezpeleta
Business Litigation · Auburn
Bar #338911 · Admitted 2021
Official record
The RegistryCounty Record · California
Tax Lawyers in Placer County, California
Searching for a tax attorney in Placer County? Counsel for the IRS and the FTB — audits, liens, and negotiated resolutions. This page indexes the county's tax coverage from the State Bar of California's official roll, with identity-verification markers where available.
A county running from the Sacramento suburbs at Roseville, its largest city, up Interstate 80 to Lake Tahoe's north shore; sustained residential growth has made it one of the faster-growing counties in Northern California, with the main courthouse in Roseville and the historic courthouse in Auburn. Venue for most tax matters arising in the county lies with the Superior Court of California, County of Placer, seated at Auburn.
Before comparing counsel, note the clock. Under 26 U.S.C. § 6501, the governing period is the IRS generally has three years from filing to assess additional tax; the FTB has four (Cal. Rev. & Tax. Code § 19057). Substantial omissions double the federal window to six years (26 U.S.C. § 6501(e)); no return or fraud means no limit. A Tax Court petition must follow a notice of deficiency within 90 days (26 U.S.C. § 6213).
The clock & the court
Statute of limitations
The IRS generally has three years from filing to assess additional tax; the FTB has four (Cal. Rev. & Tax. Code § 19057).
26 U.S.C. § 6501
Substantial omissions double the federal window to six years (26 U.S.C. § 6501(e)); no return or fraud means no limit. A Tax Court petition must follow a notice of deficiency within 90 days (26 U.S.C. § 6213).
Court of record
Superior Court of California, County of Placer.
County seat: Auburn
Official court information, locations, and filing rules: www.placer.courts.ca.gov
Tax · Placer County roster
Tax questions, cited
How far back can the IRS or the California FTB audit me?
The IRS generally has three years from the return's filing to assess more tax (26 U.S.C. § 6501), extended to six years when income is understated by more than 25% (§ 6501(e)) and unlimited for fraud or unfiled returns. The California Franchise Tax Board has four years (Cal. Rev. & Tax. Code § 19057) — and California has no collection-barring statute comparable to the IRS's ten-year rule until 20 years after assessment (§ 19255).
What can I do if I cannot pay my tax debt?
Both agencies offer structured resolutions: installment agreements (26 U.S.C. § 6159), offers in compromise settling the debt for less than owed where collection potential is limited (26 U.S.C. § 7122; FTB equivalent under Rev. & Tax. Code § 19443), and currently-not-collectible status. Penalty abatement for reasonable cause is separately available. Ignoring notices forfeits appeal rights that are often the real leverage.
What is the deadline to challenge an IRS notice of deficiency?
Ninety days from the notice date to petition the U.S. Tax Court (26 U.S.C. § 6213) — the only forum where you can litigate before paying. Miss it, and the tax is assessed; challenge then requires paying first and suing for a refund (26 U.S.C. § 7422). California FTB deficiency protests run 60 days (Rev. & Tax. Code § 19041), with appeals to the Office of Tax Appeals.
Am I responsible for my spouse's tax debt?
Joint filers are jointly and severally liable (26 U.S.C. § 6013(d)(3)), but innocent spouse relief under 26 U.S.C. § 6015 can relieve a spouse who did not know of understatements and for whom liability would be inequitable; California mirrors this in Rev. & Tax. Code § 18533. Community property rules complicate separate filings in California, which is one reason these cases benefit from counsel.
When does unpaid payroll tax become personal liability?
When the business fails to remit withheld taxes, the IRS can assess the trust fund recovery penalty — 100% of the unremitted amount — personally against any "responsible person" who willfully failed to pay (26 U.S.C. § 6672). California's EDD imposes similar personal liability (Cal. Unemp. Ins. Code § 1735). Owners, officers, and even bookkeepers with check-signing authority can be reached.
Legal information, not legal advice.
From the answer files
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Tax in nearby counties
Read the record. Then decide.
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