# Kemble White Tax Solutions > Tax controversy representation before the IRS and the California tax agencies. Kemble White spent seven years inside the IRS Office of Chief Counsel advising on collection law and more than twenty-five years in private practice limited to tax controversy. Flat fees quoted before any work begins. Santa Barbara, California; clients nationwide. Office: 2780 State Street, Suite A, Santa Barbara, CA 93105 Telephone: (805) 682-6165 | Mobile: (201) 467-9656 | Fax: (805) 845-7899 Contact: https://wvb.kow.temporary.site/contact/ Free case review: https://wvb.kow.temporary.site/free-case-review/ ## Services - [California & State Tax](https://wvb.kow.temporary.site/services/california-state-tax/): Franchise Tax Board, CDTFA and EDD matters coordinated with the federal case, so a state action does not quietly undo the federal resolution. - [IRS Audits & Appeals](https://wvb.kow.temporary.site/services/audits-appeals/): Representation through correspondence, office and field examinations, and administrative Appeals when the examiner's conclusion is simply wrong. - [IRS Tax Debt & Collections](https://wvb.kow.temporary.site/services/irs-collections/): A lien, a levy or a garnishment stops being yours to answer once representation is on file. Installment agreements, hardship status and appeals. - [Offers in Compromise](https://wvb.kow.temporary.site/services/offer-in-compromise/): Whether an offer in compromise is realistic in your case, what the IRS will actually value, and the disclosure and payment terms before you commit. - [Payroll & Trust Fund Taxes](https://wvb.kow.temporary.site/services/payroll-trust-fund/): Employment tax deposits and TFRP investigations, and the responsibility and willfulness questions that decide whether the liability becomes personal. - [Tax Investigations & Fraud](https://wvb.kow.temporary.site/services/tax-investigations/): Civil fraud penalties, special-agent contact and voluntary disclosure, handled before an examination turns into a criminal referral. - [Tax Penalties & Abatement](https://wvb.kow.temporary.site/services/tax-penalties/): First-time abatement and reasonable cause relief, including the statutory arguments the IRS will not raise on your behalf if you do not raise them. - [Unfiled & Delinquent Returns](https://wvb.kow.temporary.site/services/unfiled-returns/): Years of unfiled returns brought current and substitute-for-return assessments reversed, before the IRS files a return on your behalf and bills it. - [Worker Classification](https://wvb.kow.temporary.site/services/worker-classification/): Independent contractor versus employee disputes with the IRS and California, including Section 530 relief and EDD reclassification audits. - [Estate Planning](https://wvb.kow.temporary.site/services/estate-planning/): Wills, trusts, powers of attorney, health care directives and the tax consequences of a transfer, planned before assets change hands. Santa Barbara, California. ## Guides by topic ### IRS Collections (24) - [California Tax Liens and Levies: State-Specific Review](https://wvb.kow.temporary.site/insights/california-tax-liens-levies/): California can use liens, levies, and other collection tools under state law. The notice, agency, tax type, and procedural stage determine the available… - [Collection Due Process Hearings: Preserving IRS Appeal Rights](https://wvb.kow.temporary.site/insights/collection-due-process-hearing/): A timely Collection Due Process request can provide independent Appeals review of certain lien and levy actions and may preserve the right to seek… - [Currently Not Collectible Status: Temporary IRS Hardship Relief](https://wvb.kow.temporary.site/insights/currently-not-collectible-status-irs-hardship/): The IRS may temporarily delay collection when paying would prevent a taxpayer from meeting necessary living expenses. - [The IRS Collection Statute: Why the Account Timeline Is Complex](https://wvb.kow.temporary.site/insights/irs-collection-statute-timeline/): Federal tax collection is subject to a statutory period, but the account's actual expiration date cannot safely be estimated from the tax year alone. - [IRS Bank Levy: Immediate Steps and Documentation](https://wvb.kow.temporary.site/insights/irs-bank-levy-immediate-steps/): When a bank receives an IRS levy, federal law and the levy instructions govern how funds are held and remitted. - [IRS Form 2848: What a Tax Power of Attorney Authorizes](https://wvb.kow.temporary.site/insights/irs-form-2848-tax-power-of-attorney/): Form 2848 authorizes eligible representatives to act before the IRS for specified taxpayers, tax matters, forms, and periods. - [IRS Financial Statements: Forms 433-A, 433-B, and 433-F](https://wvb.kow.temporary.site/insights/irs-financial-statements-forms-433/): IRS collection financial statements organize information about income, expenses, assets, debts, and business activity. - [IRS Installment Agreements: How Payment Plans Are Evaluated](https://wvb.kow.temporary.site/insights/irs-installment-agreements-payment-plans/): An installment agreement allows an accepted tax balance to be paid over time. The information required and the degree of financial review depend on the… - [IRS Private Debt Collection: Verify Before You Pay](https://wvb.kow.temporary.site/insights/irs-private-debt-collection-verify-before-pay/): The IRS may assign certain inactive tax receivables to authorized private collection agencies, but taxpayers should verify the assignment through official… - [Offer in Compromise Eligibility: What the IRS Actually Reviews](https://wvb.kow.temporary.site/insights/offer-in-compromise-eligibility/): An offer in compromise is not a universal discount program. The IRS evaluates the legal basis for the offer, filing and payment compliance, financial… - [How to Respond to an IRS Wage Levy](https://wvb.kow.temporary.site/insights/respond-to-irs-wage-levy/): A wage levy can continue against later paychecks until it is released, the liability is resolved, or another terminating event occurs. - [Tax Debt After Divorce: Joint Returns and Collection Questions](https://wvb.kow.temporary.site/insights/tax-debt-after-divorce-joint-returns/): A divorce decree can allocate responsibility between former spouses, but it does not automatically rewrite federal joint-and-several liability on a joint… - [Federal Tax Lien Release, Withdrawal, Discharge, and Subordination](https://wvb.kow.temporary.site/insights/tax-lien-release-withdrawal-discharge-subordination/): Lien release, withdrawal, discharge, and subordination are different remedies. A release addresses the lien after the secured liability is satisfied or… - [IRS Tax Debt Options When You Cannot Pay in Full](https://wvb.kow.temporary.site/insights/irs-tax-debt-options-cannot-pay-in-full/): Taxpayers who cannot pay in full may have several paths, including an installment agreement, an offer in compromise when eligibility requirements are met… - [Federal Tax Lien vs. IRS Levy: The Difference Matters](https://wvb.kow.temporary.site/insights/federal-tax-lien-vs-irs-levy/): A federal tax lien is the government's legal claim against property after required conditions are met. - [What to Do After Receiving an IRS Collection Notice](https://wvb.kow.temporary.site/insights/what-to-do-after-irs-collection-notice/): Read the entire notice, identify the tax period and response date, compare it with your records, and respond through the channel stated in the notice. - [Paying For College](https://wvb.kow.temporary.site/insights/paying-for-college/): Why college costs rose thirty-fold in fifty years, and how tax-aware saving changes what a family actually has to earn to pay tuition. - [Newsletter – February 2018](https://wvb.kow.temporary.site/insights/newsletter-february-2018/): February 2018 letter on planning for education costs, and why a penny saved is worth more than a penny earned once income tax is counted. - [Newsletter – October 2017](https://wvb.kow.temporary.site/insights/newsletter-october-2017/): October 2017 letter: help with tax problems, financial planning for school costs, and general legal review. Referrals valued. - [2016 Changes in IRS Collection Practices](https://wvb.kow.temporary.site/insights/2016-changes-in-irs-collection-practices/): Private debt collectors and other changes in how the IRS pursued accounts from 2016, and what each one meant for taxpayers receiving contact. - [Newsletter – September 2011](https://wvb.kow.temporary.site/insights/newsletter-september-2011/): Why limiting a practice to tax controversy — unfiled returns, collection, audits and Tax Court — makes the work faster and more predictable. - [Swiss Banks Cave on Bank Secrecy](https://wvb.kow.temporary.site/insights/swiss-banks-cave-on-bank-secrecy/): In 2013 Switzerland agreed to let its banks disclose information on American clients with hidden accounts. Why it was a turning point. - [The Trouble With Tax Relief Firms](https://wvb.kow.temporary.site/insights/the-trouble-with-tax-relief-firms/): Tax problems create urgency and advertising exploits it. An offer in compromise is a real procedure, not proof that anyone can settle cheaply. - [Trouble In The Legal Industry](https://wvb.kow.temporary.site/insights/trouble-in-the-legal-industry/): Law schools produce roughly twice the lawyers the industry has jobs for. Notes on The Lawyer Bubble and what the school rankings actually measure. ### Audits & Appeals (10) - [CP2000 Notice: Income Matching Is Not a Formal Audit](https://wvb.kow.temporary.site/insights/cp2000-notice-how-to-respond/): A CP2000 generally proposes changes after IRS information returns do not match the filed return. - [Audit Reconsideration After an IRS Assessment](https://wvb.kow.temporary.site/insights/irs-audit-reconsideration-after-assessment/): Audit reconsideration is an administrative process that may allow the IRS to reevaluate an assessment when a taxpayer did not participate fully in the… - [IRS Audit Substantiation When Receipts Are Missing](https://wvb.kow.temporary.site/insights/irs-audit-missing-receipts-substantiation/): Missing a receipt does not automatically prove or disprove an expense. The question is whether reliable records and legally acceptable evidence can… - [IRS Appeals: Building a Clear Protest](https://wvb.kow.temporary.site/insights/irs-appeals-build-clear-protest/): A persuasive IRS Appeals submission identifies each disputed adjustment, the relevant facts, the law or administrative authority, and the evidence… - [Preparing for an IRS Office or Field Audit](https://wvb.kow.temporary.site/insights/prepare-for-irs-office-field-audit/): An in-person examination requires advance work on the return, records, likely questions, and scope. - [How to Respond to a Correspondence Audit](https://wvb.kow.temporary.site/insights/respond-to-irs-correspondence-audit/): A correspondence audit is conducted primarily by mail or secure electronic exchange. - [The Taxpayer Bill of Rights in Audits and Collections](https://wvb.kow.temporary.site/insights/taxpayer-bill-of-rights-audits-collections/): The Taxpayer Bill of Rights organizes ten fundamental rights, including rights to information, quality service, payment of no more than the correct tax… - [IRS Audit Letters: How to Identify the Type of Examination](https://wvb.kow.temporary.site/insights/irs-audit-letters-types-of-examination/): IRS examinations may be handled by correspondence, in an IRS office, or in the field. - [Audit Statistics: What Are the Chances of Being Audited?](https://wvb.kow.temporary.site/insights/audit-statistics/): The IRS examined 0.6% of returns filed in 2015. Audit odds rise with adjusted gross income, and most individual audits are now computer-handled. - [The Underground Economy](https://wvb.kow.temporary.site/insights/the-underground-economy/): U.S. citizens and residents are taxed on worldwide income. How much of it is actually declared, and what the underground economy costs. ### Filing & Compliance (10) - [Amended Tax Returns: When a Correction Is Worth Filing](https://wvb.kow.temporary.site/insights/amended-tax-return-when-to-file/): An amended return is used to correct a previously filed return, but the decision should account for the legal issue, evidence, refund limitation periods… - [How to Choose a Tax Resolution Professional](https://wvb.kow.temporary.site/insights/choose-tax-resolution-professional/): Choose a tax professional by matching verified credentials and relevant case experience to the actual problem. - [IRS Substitute for Return: Why the Assessment May Be Too High](https://wvb.kow.temporary.site/insights/irs-substitute-for-return-assessment/): When a required return is not filed, the IRS may prepare a substitute for return using available information. - [How to Read an IRS Account Transcript Before Choosing a Resolution](https://wvb.kow.temporary.site/insights/read-irs-account-transcript-tax-resolution/): An IRS account transcript is a coded history of assessments, payments, credits, returns, and selected account events. - [Tax Court Petition Deadlines: Why the Notice Controls](https://wvb.kow.temporary.site/insights/tax-court-petition-deadline-notice-controls/): A notice that grants the right to petition the United States Tax Court states a deadline. - [Tax Record Retention: Build a Defensible File, Not Just a Box of Receipts](https://wvb.kow.temporary.site/insights/tax-record-retention-defensible-file/): Tax records should be kept long enough to support returns, basis, carryovers, payroll duties, and transactions under the limitation periods that may… - [How Tax Refunds Are Applied When You Owe the IRS](https://wvb.kow.temporary.site/insights/tax-refund-offset-when-you-owe-irs/): When a taxpayer owes an assessed federal balance, a later refund may be applied to that debt. - [Unfiled Tax Returns: A Step-by-Step Compliance Plan](https://wvb.kow.temporary.site/insights/unfiled-tax-returns-compliance-plan/): Resolving unfiled returns starts with determining which returns are required, reconstructing reliable records, and filing accurate returns in the correct… - [Immigration Tax Problems](https://wvb.kow.temporary.site/insights/immigration-tax-problems/): If immigration reform requires filing unfiled returns and paying what is owed, three approaches to compliance are likely. Written in 2013. - [Tax Extensions – Good or Bad?](https://wvb.kow.temporary.site/insights/tax-extensions-good-or-bad/): An extension gives you more time to file, not more time to pay. What that distinction costs in interest and penalties once the deadline passes. ### Tax Investigations (10) - [Civil Tax Fraud vs. a Criminal Tax Investigation](https://wvb.kow.temporary.site/insights/civil-tax-fraud-vs-criminal-investigation/): Civil fraud can produce tax additions through an administrative and civil process; a criminal investigation can lead to prosecution and punishment. - [FBAR and Foreign Account Compliance: Choosing the Correct Procedure](https://wvb.kow.temporary.site/insights/fbar-foreign-account-compliance-options/): Late or inaccurate foreign account and asset reporting can involve several forms and different procedures. - [IRS Identity Theft and Fraudulent Tax Returns](https://wvb.kow.temporary.site/insights/irs-identity-theft-fraudulent-tax-return/): Tax-related identity theft can involve a return filed with a stolen Social Security number, altered account information, or fraudulent refund activity. - [What to Do If an IRS Special Agent Contacts You](https://wvb.kow.temporary.site/insights/irs-special-agent-contact/): An IRS Criminal Investigation special agent investigates potential federal crimes. - [IRS Voluntary Disclosure: A Compliance Practice, Not Amnesty](https://wvb.kow.temporary.site/insights/irs-voluntary-disclosure-practice/): The IRS Criminal Investigation Voluntary Disclosure Practice may be relevant to taxpayers whose noncompliance was willful and who seek to return to… - [Celebrities – Tax Evasion Doesn’t Pay](https://wvb.kow.temporary.site/insights/celebrities-tax-evasion-doesnt-pay/): Celebrity tax cases show the pattern: the IRS has more time, more data and more patience than the people trying to hide income from it. - [IRS Criminal Investigation](https://wvb.kow.temporary.site/insights/irs-criminal-investigation/): Criminal investigations at the IRS run through roughly 2,600 special agents, then review by Chief Counsel and referral to the Department of Justice. - [Reporting Foreign Income and Interests in Foreign Entities](https://wvb.kow.temporary.site/insights/irs-data-mining-snares-mostly-low-and-middle-income-taxpayers/): The IRS uses robo-audits and data mining, reaching credit card records, social media and medical records. So far it catches mostly small cases. - [U.S. Offshore Account Enforcement Issues](https://wvb.kow.temporary.site/insights/u-s-offshore-account-enforcement-issues/): A digest of the 2013 NYU Tax Controversy Institute presentation on offshore account enforcement, information sharing between governments and penalties. - [Voluntary Disclosures](https://wvb.kow.temporary.site/insights/voluntary-disclosures/): The IRS voluntary disclosure policy lets taxpayers with criminal exposure come forward through Criminal Investigation and settle without prosecution. ### California & State (5) - [California FTB Payment Plans and Financial Hardship](https://wvb.kow.temporary.site/insights/california-ftb-payment-plan-financial-hardship/): California taxpayers who cannot pay in full may be able to request a payment arrangement or other relief based on the account and current FTB procedures. - [California Offer in Compromise: Who May Qualify](https://wvb.kow.temporary.site/insights/california-offer-in-compromise/): The California FTB has an offer-in-compromise program for eligible taxpayers who cannot pay their tax liability in the foreseeable future. - [IRS and California Tax Debt: Coordinating Two Agencies](https://wvb.kow.temporary.site/insights/irs-and-california-tax-debt-coordination/): A taxpayer may owe both the IRS and California for related years, but each agency has its own balance, notices, financial review, payment arrangements… - [California FTB Collection Notices: How to Build a Response](https://wvb.kow.temporary.site/insights/california-ftb-collection-notice-response/): A California Franchise Tax Board collection notice should be matched to the taxpayer, tax year, assessment, payments, and stated response rights. - [Sales Tax Comes Back to Bite Online Buyers](https://wvb.kow.temporary.site/insights/sales-tax-comes-back-to-bite-online-buyers/): Twenty-four states ask filers to report untaxed out-of-state purchases. How use tax works and why online buyers are asked to document it. ### Employment Taxes (5) - [Employee or Independent Contractor? A Tax Classification Framework](https://wvb.kow.temporary.site/insights/employee-vs-independent-contractor-tax-classification/): Worker classification depends on the actual relationship, especially behavioral control, financial control, and the relationship of the parties. - [Payroll Tax Deposits: Why Timing and Classification Matter](https://wvb.kow.temporary.site/insights/payroll-tax-deposits-timing-classification/): Employment tax compliance requires correct worker classification, withholding, deposits, returns, and information reporting. - [Responsible Person and Willfulness in a TFRP Investigation](https://wvb.kow.temporary.site/insights/tfrp-responsible-person-willfulness/): TFRP responsibility focuses on meaningful authority over financial decisions; willfulness generally concerns a voluntary, conscious, and intentional… - [Trust Fund Recovery Penalty: Personal Exposure for Payroll Taxes](https://wvb.kow.temporary.site/insights/trust-fund-recovery-penalty-personal-liability/): The Trust Fund Recovery Penalty can make responsible and willful individuals personally liable for the trust-fund portion of unpaid employment taxes. - [Cancellation of Indebtedness Income](https://wvb.kow.temporary.site/insights/cancellation-of-indebtedness-income/): Section 61 includes income from discharge of indebtedness. What a Form 1099-C from a foreclosure, short sale or written-off debt means on a return. ### Penalties & Relief (4) - [First-Time Penalty Abatement: What It Does and Does Not Cover](https://wvb.kow.temporary.site/insights/first-time-penalty-abatement/): The IRS's administrative first-time abatement policy may remove certain common penalties when compliance-history and filing requirements are met. - [IRS Penalty Abatement for Reasonable Cause](https://wvb.kow.temporary.site/insights/irs-penalty-abatement-reasonable-cause/): Reasonable-cause relief is a fact-specific analysis of whether the taxpayer exercised ordinary business care and prudence but could not comply. - [Newsletter — July 2018](https://wvb.kow.temporary.site/insights/newsletter-july-2018/): A summary of the Tax Cuts and Jobs Act as enacted in December 2017, drawn from the 2018 U.S. Master Tax Guide. Written in 2018. - [Problems at the IRS](https://wvb.kow.temporary.site/insights/problems-at-the-irs/): Beyond the targeting scandal: the funding, staffing and complexity problems the IRS lives with, summarised from The Economist. ### Taxpayer Rights (3) - [Innocent Spouse Relief: Three Paths and the Evidence They Require](https://wvb.kow.temporary.site/insights/innocent-spouse-relief-paths-evidence/): Federal law provides more than one form of relief from joint-return liability. Eligibility turns on the kind of understatement or underpayment, marital… - [Tax Relief Scams: Red Flags Before You Sign](https://wvb.kow.temporary.site/insights/tax-relief-scam-red-flags/): Tax relief scams often use guaranteed reductions, urgent threats, vague credentials, large upfront fees, and salespeople who promise a result before… - [Tax Scams and Consumer Alerts](https://wvb.kow.temporary.site/insights/tax-scams-consumer-alerts/): Scammers use mail, telephone and email to target taxpayers, businesses and payroll professionals. How the contacts work and where to verify them. ## About - [Who we are](https://wvb.kow.temporary.site/about/) - [Contact](https://wvb.kow.temporary.site/contact/) ## Note The material on this site is general and does not constitute legal or tax advice. Reading it does not create an attorney-client relationship.