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 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 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.