Tax Attorney

Edgar Law Group, LLP — a respected tax law firm in San Jose — is seeking an accomplished Tax Attorney to join our growing team. This is a unique opportunity to lead sophisticated federal and state controversy matters for high-net-worth individuals, closely held businesses, and nonprofits, while partnering on proactive tax planning that reduces risk and advances client goals. Responsibilities Represent clients before the IRS and California taxing authorities across all stages of controversy, including examinations, Appeals, and U.S. Tax Court. Handle complex dispute resolution matters such as audit defense, appeals, Collection Due Process (CDP) hearings, Trust Fund Recovery Penalty cases, Offers in Compromise (OIC), installment agreements, penalty abatements, and passport/levy releases. Advise on sensitive areas including employment tax, ERC audits, international reporting (FBAR/Forms 3520/5471/5472/8938), and high-dollar civil penalty exposure. Coordinate with our Legal & Tax Teams on entity structuring, basis and loss limitation issues, reasonable compensation, and tax-efficient exit strategies to prevent repeat controversy. Draft persuasive protest letters, position memos, and closing agreements; develop documentation strategies that withstand IRS scrutiny. Work closely with the Managing Partner (an attorney-CPA) and a tight-knit legal team in a boutique environment that values precision, integrity, and proactive problem-solving. Key Focus Areas IRS and state collections, audit, and appeals representation, including direct negotiation with revenue officers, appeals agents, and agency counsel. Legal drafting for Tax Court petitions, estate plans, trust instruments, settlement proposals, and advisory memoranda. Research and resolution of complex tax and estate issues involving foreign disclosures, pass-throughs, trusts, probate, and business succession. Strategic estate and tax planning in coordination with real estate, probate, and corporate counsel. Qualifications Juris Doctor (JD) from an accredited U.S. law school; active membership in the California Bar in good standing is required. 3–5 years of experience practicing law in tax, estate planning, and related disciplines. Proven success advising and representing clients before the IRS and California taxing authorities, including audits, appeals, collections, and settlement negotiations. Familiarity with Tax Court procedure, tax controversy, and administrative filings is preferred. Demonstrated ability to analyze and structure transactions—such as entity formations, reorganizations, and buy-sell or exit planning—craft clear tax advice, and implement practical, business-minded solutions. Strong research and drafting skills with command of the Internal Revenue Code, Treasury Regulations, and relevant federal and California case law or administrative guidance (e.g., FTB, CDTFA). Experience collaborating with CPAs and EAs on return positions, documentation, and compliance calendars; proven ability to manage document-intensive matters with rigor and discretion. Strong interpersonal skills and a client-centered mindset, with professionalism and emotional intelligence in every interaction. Thorough understanding of federal and California tax law, including income, estate, and gift tax planning, as well as probate administration. Exceptional legal research, writing, and analytical skills, with a demonstrated ability to provide thoughtful, actionable advice. Comfortable managing matters independently while contributing meaningfully in a collaborative, cross-functional team environment. Bonus: Experience in estate and wealth-