California FTB Audit Defense
Protect Every Dollar.

FTB audits are thorough, aggressive, and unforgiving. We’ve defended hundreds of California taxpayers against FTB examinations — and we know exactly how to fight back.

Sam BrotmanSam Brotman, J.D., LL.M.

Last updated July 2026

Key Takeaway

An FTB audit is not the same as an IRS audit. California’s Franchise Tax Board uses different procedures, different standards, and different settlement practices — and the penalties for mishandling the process are severe.

An FTB Audit Letter Is Just the Beginning.

When the California Franchise Tax Board sends an audit notice, they’ve already reviewed your return and identified what they believe are discrepancies. The question isn’t whether they’ll find something — it’s how much they’ll try to assess.

FTB auditors are trained to maximize adjustments. They’ll request broad documentation, apply the strictest interpretations of California tax law, and push for the largest possible assessment. Without professional representation, you’re at a significant disadvantage.

We handle your FTB audit from the first response letter through final resolution. We know which documents to provide, which requests to push back on, and how to present your position in the strongest possible light.

See our criminal tax defense page for more on eggshell audits and what happens when a civil exam transitions to a criminal investigation.

From Our Practice

We’ve handled hundreds of FTB audits — from straightforward residency examinations to complex multi-year income adjustments. The FTB’s audit process is fundamentally different from the IRS, and understanding those differences is critical to protecting your position at every stage.

Talk to a Tax Attorney

Free 15-minute call. No obligation. We'll tell you exactly where you stand.

What We Handle

FTB Audit Defense Service

Correspondence Audits

FTB desk audits conducted by mail. We craft strategic responses that provide exactly what's needed to resolve the inquiry without expanding the scope of review.

Field Audits

When FTB auditors want to examine your books in person, we manage the entire process — scheduling, document preparation, and representing you at every meeting.

Residency Audits

California's most complex and highest-stakes audits. We build comprehensive residency defense packages that document your domicile with irrefutable evidence.

Business Audits

FTB examinations of partnerships, S-corporations, and C-corporations. We defend against income adjustments, expense disallowances, and apportionment challenges.

Protest & Appeal

When the FTB issues an unfavorable assessment, we file protests and represent you before the Office of Tax Appeals to reverse their findings.

Penalty Defense

California penalties — late filing, late payment, accuracy-related, and fraud — can add 25-75% to your bill. We fight for abatement on every penalty.

Understanding the Process

FTB Audits: What to Expect

What triggers an FTB audit?

The FTB selects returns using data matching (comparing your return to W-2s, 1099s, K-1s, and other information returns), statistical models that flag unusual deductions or income patterns, and specific compliance initiatives

Residency audits are triggered by events like filing a part-year return, vehicle registration changes, voter registration in another state, or tips from third parties.

What documents will the FTB request?

FTB audit requests are typically broad. They may ask for bank statements, credit card records, receipts, contracts, entity documents, and personal records like cell phone bills and travel itineraries.

We review every request and provide only what is required and strategically beneficial. Over-producing documents is one of the most common mistakes taxpayers make.

What happens if I disagree with the FTB's findings?

You have the right to protest a Notice of Proposed Assessment within 60 days. We file detailed protests supported by legal authority and documentary evidence. If the protest is denied, you can appeal to the Office of Tax Appeals (OTA).

OTA decisions are public and set important precedents. Having attorneys who understand this forum is critical to your success.

Can the FTB audit multiple years at once?

Yes. The FTB frequently expands audits to cover multiple tax years, especially in residency cases. If they identify an issue in one year, they’ll typically look at surrounding years too.

We work to contain audit scope and prevent multi-year expansions that can multiply your exposure.

Talk to a Tax Attorney

Not Sure Where You Stand?

Schedule a free 15-minute call. We’ll assess your situation, outline your options, and tell you exactly what to expect — no obligation.

or call (619) 378-3138