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Tax Attorney
Tax AttorneyEdgar Law Group, LLP • San Jose, CA, United States
Tax Attorney

Tax Attorney

Edgar Law Group, LLP • San Jose, CA, United States
8 days ago
Job type
  • Full-time
Job description

Overview

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-transfer planning (revocable and irrevocable trusts, charitable vehicles, FLPs / FLLCs) and coordinating income-tax implications with gift and estate strategies.

    • Compensation

    $150,000 per year

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