Sales Tax Audit Appeals

Challenging a CDTFA audit determination

When a CDTFA audit produces an assessment you believe is incorrect, excessive, or based on flawed methodology, you have the right to appeal. The appeals process is formal and procedurally demanding — experienced representation significantly improves outcomes.

We represent clients at every level of the California sales tax appeals process, from exit conferences with audit supervisors through formal proceedings before the Office of Tax Appeals (OTA).

Levels of appeal we handle

• Exit conferences with audit supervisors prior to final assessment
• CDTFA Appeals Bureau — informal appeal conferences
• Office of Tax Appeals (OTA) — formal hearing representation
• Petition for rehearing and reconsideration at OTA

How we build your appeal

A strong appeal is built on facts, records, and legal authority — not just disagreement with the auditor's conclusions. We analyze the audit workpapers in detail, identify errors in sampling methodology, incorrect application of law, and factual mischaracterizations. We draft the formal appeal brief, gather supporting documentation, and present your case persuasively.

Common grounds for appeal

• Flawed statistical sampling that overstates the error rate
• Incorrect taxability determinations on specific transactions
• Failure to account for valid exemption certificates
• Improper use-tax assessments on exempt purchases
• Misapplication of California sales and use tax law
• Procedural errors that affected the audit outcome

Time limits are strict

California law imposes strict deadlines on filing appeals. Missing a deadline can permanently forfeit your right to challenge an assessment. If you've received a CDTFA Notice of Determination or Notice of Redetermination, contact us immediately to protect your appeal rights.