Edgar Law Group, LLP — a respected tax law firm in San Jose — is hiring a Corporate & Tax Attorney to help clients resolve high-stakes tax matters and build smarter business structures going forward. You’ll lead federal and state controversy work for high-net-worth individuals, closely held businesses, and nonprofits, and you’ll also advise on entity formation, governance, restructurings, and transaction support that aligns legal architecture with tax strategy. This is a unique opportunity to do technically rigorous work with real-world business impact, alongside a team that values clarity, craftsmanship, and client trust. 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 including 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 and high-exposure areas such as employment tax controversies (including ERC audits), international reporting and disclosure (FBAR; Forms 3520/5471/5472/8938), and significant civil penalty exposure. • Serve as counsel on matters that intersect with tax risk, including entity formation and governance, restructurings, equity and ownership changes, contract review, and transaction support for closely held businesses and nonprofits. • Partner with the Legal & Tax teams on entity structuring, basis and loss limitation issues, reasonable compensation, and tax-efficient exit strategies designed to prevent repeat controversy. • Draft persuasive protests, position memoranda, settlement proposals, closing agreements, and documentation strategies that are defensible under IRS scrutiny and aligned with business realities. • Collaborate closely with the Managing Partner (attorney-CPA) and a tight-knit boutique team that values precision, integrity, ownership, and proactive problem-solving. Qualifications: • Juris Doctor (JD) from an accredited U.S. law school and active membership in the California Bar in good standing (required). • 3–5+ years of relevant practice experience in tax controversy and planning, with meaningful exposure to corporate matters and/or estate planning. • Bonus: estate and wealth-transfer planning experience (revocable/irrevocable trusts, charitable planning, FLPs/FLLCs) and ability to integrate income-tax implications with gift and estate strategies. • Demonstrated success representing clients before the IRS and California taxing authorities (e.g., FTB, CDTFA) across audits, appeals, collections, and settlement negotiations. • Strong working knowledge of U.S. Tax Court procedure and controversy filings (preferred). ability to analyze and structure transactions—entity formations, reorganizations, governance changes, and buy-sell/exit planning—while delivering clear, practical tax advice grounded in business realities. • Strong research and drafting skills with command of the Internal Revenue Code, Treasury Regulations, and applicable federal and California authorities and administrative guidance. • Experience collaborating with CPAs and EAs on return positions, documentation strategy, and compliance calendars; comfortable managing document-intensive matters with rigor, discretion, and attention to detail. • Excellent judgment, client presence, and communication skills, with professionalism and emotional intelligence in every interaction. • Solid understanding of federal and California tax planning concepts, including income tax and (as applicable) estate and gift planning and probate administration. • Comfortable owning matters independently while contributing meaningfully in a collaborative, boutique team environment. Compensation: $150,000 yearly

• 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 including 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 and high-exposure areas such as employment tax controversies (including ERC audits), international reporting and disclosure (FBAR; Forms 3520/5471/5472/8938), and significant civil penalty exposure. • Serve as counsel on matters that intersect with tax risk, including entity formation and governance, restructurings, equity and ownership changes, contract review, and transaction support for closely held businesses and nonprofits. • Partner with the Legal & Tax teams on entity structuring, basis and loss limitation issues, reasonable compensation, and tax-efficient exit strategies designed to prevent repeat controversy. • Draft persuasive protests, position memoranda, settlement proposals, closing agreements, and documentation strategies that are defensible under IRS scrutiny and aligned with business realities. • Collaborate closely with the Managing Partner (attorney-CPA) and a tight-knit boutique team that values precision, integrity, ownership, and proactive problem-solving.