TAX CONTROVERSY & IRS DEFENSE

Protecting What You've Built. Defending What Matters.

Tax attorney Cassra Minai, Esq. represents individuals and businesses in IRS and California tax matters, from audits and appeals through the U.S. Tax Court, and also handles tax returns and business and nonprofit compliance.

Your Attorney

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EDUCATION
J.D. with Tax Concentration (Honors), Quinnipiac University School of Law
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LEADERSHIP
Chair, ABA Business Law Section Tax Committee
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EXPERIENCE
Seven years of tax controversy and litigation experience
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ADMITTED
State Bar of California and U.S. Tax Court
7
Years Tax Controversy Experience
ABA
Tax Committee Chair
J.D.
Tax Concentration, Honors
100%
Confidential Consultations
WHAT WE HANDLE

Tax Controversy and Compliance

We represent individuals, business owners and organizations in federal and California tax matters, and help clients meet their filing obligations before problems arise.

IRS Audit Defense

Correspondence, office and field examinations, from the first IRS letter through Appeals.

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Tax Court Litigation

Petitions and litigation in the U.S. Tax Court in deficiency, collection due process and innocent spouse cases.

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California FTB Disputes

Franchise Tax Board audits, residency examinations, protests and appeals to the Office of Tax Appeals.

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Business & Personal Tax Returns

Federal and California returns for individuals, partnerships, LLCs and corporations, prepared by a tax attorney.

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Small Business Compliance

Statements of Information, annual taxes, corporate records, payroll and sales tax registration, and revival of suspended entities.

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Nonprofit Formation & Compliance

Formation, federal and California tax exemption, Attorney General registration and the annual filings that keep exemption in place.

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FBAR & Foreign Accounts

FBAR and Form 8938 reporting, the IRS programs for correcting past years, and FBAR penalty matters.

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Criminal Tax Defense

IRS Criminal Investigation inquiries, grand jury subpoenas and voluntary disclosure decisions.

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Business Tax Disputes

Employment tax examinations, trust fund recovery penalty assessments and business audits.

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Offers in Compromise

Offers in compromise, installment agreements and other options for resolving tax balances with the IRS.

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High Net Worth Defense

Examinations involving high-income individuals, closely held businesses and complex holdings.

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Tax Guides

Plain-language guides to IRS audits, appeals, collections, California tax and business compliance.

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WHY ADVANTAGE TAX LAW

Direct Counsel From a Tax Attorney

Every matter is handled personally by Cassra Minai, Esq., with a focus on careful analysis, clear communication and well-documented positions.

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ABA Tax Committee Chair

Chair of the American Bar Association Business Law Section Tax Committee.

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Direct Attorney Contact

You work directly with your attorney from the first consultation through resolution.

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Attorney-Client Privilege

Communications with your attorney are generally privileged, including in criminal tax matters, where the limited CPA and enrolled agent privilege (IRC Β§7525) does not apply.

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Litigation Experience

Admitted to the State Bar of California and the U.S. Tax Court, with seven years of experience handling tax controversies and litigation.

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Every tax controversy case is different, but the approach is always the same: understand the full picture, build the strongest possible position, and fight for the best outcome. That is what this firm was built to do.

Cassra Minai, Esq. β€” Founding Attorney

J.D.
TAX CONCENTRATION, HONORS
ABA
TAX COMMITTEE CHAIR
FOR HIGH NET WORTH CLIENTS

You Have More at Stake. We Understand That.

IRS data show that examination rates rise with income. For tax year 2021, the IRS reports examination coverage of 6.6 percent for returns reporting total positive income of $10 million or more (IRS Data Book, FY 2025). These matters often involve closely held businesses, partnerships and foreign holdings, and they reward careful preparation from the first contact.

01

High-Income Examinations

The IRS examines a larger share of returns as income rises. We represent high-income individuals and their businesses in field examinations and Appeals.

02

Foreign Accounts and Assets

Unreported foreign accounts and assets can carry significant civil penalties and, in willful cases, criminal exposure. We evaluate the available compliance options before anything is filed.

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Business Owner Disputes

Partnership audits, S corporation reasonable compensation issues and trust fund recovery penalties, handled with both the business and the owner’s personal exposure in view.

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Charitable Organizations

Forming a nonprofit or private charity involves federal and California exemption applications and annual filings with the IRS, the Franchise Tax Board and the Attorney General. We handle formation and ongoing compliance.

Discretion

Consultations are confidential, and communications made to obtain legal advice are protected by the attorney-client privilege. Privacy is part of how we work.

Nationwide Representation

We represent clients before the IRS and the U.S. Tax Court regardless of where they live. The firm is based in Irvine, California.

Planning Ahead

Much of the work that prevents disputes happens before a return is filed: documenting positions, keeping entities in good standing and meeting reporting deadlines.

HOW IT WORKS

From First Call to Resolution

Every matter begins with a confidential conversation and an honest assessment of where you stand and what can be done.

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Confidential Consultation

We review your situation in confidence and identify the issues that matter most.

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Case Analysis

We review the documents, deadlines and legal options in detail.

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Strategic Plan

We recommend a course of action and explain the alternatives, costs and next steps.

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Resolution

We carry out the plan, keep you informed, and work toward a resolution that limits your exposure.

TAKE THE FIRST STEP

Let’s Talk About Your Situation.

Deadlines in tax matters are strict, and early advice often leaves more options open. Consultations are confidential and free of charge.

(949) 260-4729

Tax Code & Form Lookup

Plain-English summaries of federal and California tax code sections and IRS forms, each linked to the full statute or the agency’s form page. General information only, not legal advice.

Tax Court Portal & IRS Audit Data

IRS Audit Statistics

Published IRS figures. IRS fiscal years run from October 1 to September 30. Recommended amounts are proposed by examiners and are not amounts collected.

Audit Rates for High-Income Individuals (Tax Year 2021)

Share of tax year 2021 individual returns examined, by total positive income, counting audits closed or in process through September 30, 2025. Source: IRS Data Book, FY 2025.

Tax Return Audits Closed: FY 2016 and FY 2025

All return types. Sources: IRS Data Book, FY 2016 (Table 9a: 1,166,379 returns examined) and IRS Data Book, FY 2025 (497,621 audits closed).

Additional Tax Recommended or Assessed in FY 2025, by IRS Program

Billions of dollars, as recommended or assessed (not amounts collected). Audits closed in FY 2025 recommended $26.8 billion, of which field audits accounted for $19.1 billion; the Automated Substitute for Return figure is reported as nearly $2.9 billion. Source: IRS Data Book, FY 2025.

Areas of IRS Focus

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Income that does not match information returns
IRS matching program
The IRS compares income reported on Forms W-2, 1099 and other information returns with the amounts on filed returns. Its Automated Underreporter program closed 987,460 cases in fiscal year 2025, often after sending a CP2000 notice proposing changes.
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Syndicated conservation easements
Listed transaction
Final regulations (T.D. 10007, effective October 8, 2024) identify certain syndicated conservation easement transactions as listed transactions, building on Notice 2017-10. Participants and material advisors must disclose them to the IRS.
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Micro-captive insurance arrangements
Reportable transaction
Final regulations (T.D. 10029, effective January 14, 2025) identify certain micro-captive insurance arrangements as listed transactions and others as transactions of interest. Participants and material advisors must disclose them to the IRS.
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Returns that are not filed
IRS priority
When a required return is not filed, the IRS can prepare a substitute return based on the information returns it has received. Its Automated Substitute for Return program closed 592,773 cases in fiscal year 2025, resulting in nearly $2.9 billion in additional assessments.

Notable Tax Cases

Summaries of selected published decisions of the U.S. Tax Court, other federal courts and the Supreme Court. These cases involved other taxpayers and are not matters handled by Advantage Tax Law. They are provided for general information and do not predict the outcome of any other case. Results are shown from the taxpayer’s point of view and reflect later appeals known as of October 2026.

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Insights & Resources

Have Questions About Your Tax Situation?

Every case is different. Schedule a confidential consultation to discuss your specific circumstances with an experienced tax attorney.