Mr. Disparte is a Los Angeles tax litigation attorney. He has extensive experience in the field of tax controversy. His practice centers on representing individuals and businesses before the Internal Revenue Service (IRS), Franchise Tax Board (FTB), Employment Development Department (EDD), and State Board of Equalization (SBOE). Mr. Disparte also represents taxpayers in criminal proceedings before state and federal courts. Mr. Disparte is an adjunct professor of tax procedure and controversy at UCSD.
Prior to establishing Disparte Tax Law, Mr. Disparte was a senior tax attorney for many years with a prominent law firm in San Diego where he practiced in the fields of civil and criminal tax controversy. After graduating from law school, Mr. Disparte worked as a law clerk to several judges of the Superior Court in Los Angeles. He also has experience in business law and civil litigation. Mr. Disparte has successfully defended taxpayers in tax audits, Tax Court litigation, criminal investigations, offshore voluntary disclosures and compliance matters, administrative appeals, claims for refund and sensitive tax collection cases. Mr. Disparte has presented on similar topics to tax practitioners throughout Southern California.
Mr. Disparte received his LL.M. in Taxation with Distinction and received Dean’s List honors from Georgetown University Law Center. He also earned his Juris Doctor in 2009 with honors from Brigham Young University. During law school, Mr. Disparte served as an editor and board member for the International Law and Management Review, and he was a member of his law school’s award-winning Vis International Arbitration Moot Court team.
- Successfully resolved criminal tax fraud charges. Represented a taxpayer in a criminal tax case with a tax loss of over $800,000. Taxpayer entered a plea that required no jail time.
- Represented a taxpayer with an innocent spouse relief claim. The IRS granted the request in full reducing the client’s tax liability by over $800,000.
- After conducting a deposition of the alleged thief, successfully persuaded IRS Counsel to accept a taxpayer’s claimed theft loss of over $1 million.
- Represented a taxpayer in an IRS criminal investigation and was able to persuade the Criminal Investigation agent and federal prosecutor to drop any and all potential charges.
- Successfully guided many clients through voluntary disclosures of their foreign bank accounts and advised on complex FBAR issues.
- Represented a taxpayers in docketed and un-docketed appeals with millions of dollars in proposed taxes.
- Successfully resolved IRS payroll audits.
- Successfully defended taxpayers against successor liability claims and alter ego claims by the IRS collections department.
- Represented a taxpayer whose spouse had passed away with a large IRS and FTB tax liability; convinced the IRS and FTB to not attempt to collect on the surviving spouse’s tax liability.
- Represented a taxpayer in an SBOE audit and received a no-change (no additional tax was assessed) and the audit was finished after one meeting.
- Represented a taxpayer with a complicated business in an IRS audit. Taxpayer had minimal receipts to substantiate his expenses. Taxpayer received a no-change audit with no tax assessment by the IRS.
- Helped taxpayers with over a million dollars in tax liabilities to establish affordable installment agreements.
- Planned many successful offers in compromise, saving taxpayers over one million dollars in tax liabilities.
- Convinced the IRS to accept a disregarded C corp and saved the taxpayer hundreds of thousands of dollars in proposed tax assessments.
- Persuaded the IRS to exclude debt discharge income created by a foreclosure of a rental property; saved client hundreds of thousands of dollars in proposed taxes.
- Prevented an IRS revenue officer from issuing a levy against a taxpayers clients; saved the client’s business from being shut down.
- Successfully concluded an FTB audit and persuaded the FTB not to assert any penalties against the taxpayer.
- Represented a taxpayer in a sales tax audit; saved the taxpayer over $2 million in taxable measure.
- Successfully assisted a taxpayer in excluding debt discharge income; saved the taxpayer over $100,000.
- Successfully defended a tax return attorney against significant penalties that were assessed by the IRS.
- Successfully defended clients from levies and liens by the IRS and FTB.
- Successfully appealed a levy on a taxpayer’s wages and obtained a refund of the levy.
- Assisted taxpayers in obtaining Non-profit status with the IRS and FTB.
- Successfully represented clients in penalty abatements.
- Successfully represented clients in EDD audits saving them penalties and lowering their tax assessment.
- Rising Star 2017, Superlawyers
- Best of the Bar – San Diego Business Journal 2016
- Top Young Attorney 2013, San Diego Daily Transcript
- Adjunct Professor at UCSD
- Course taught: Tax Practice, Procedure and Ethics
Admitted to Practice before the following Courts
- United States District Court – Central District of California
- United States District Court – Southern District of California
- Supreme Court of California
- U.S. Tax Court
- American Bar Association
- J. Reuben Law Clark Law Society
- Moderator, University of San Diego School of Law – RJS Law Tax Controversy Institute, Offshore Voluntary Disclosure Program Panel (2016)
- International tax Compliance Issues and IRS audits Panelist, CSEA San Diego Chapter (2016)
- Appeals, Collections & Offshore Voluntary Disclosure Program, California Society of Tax Consultants (2015)
- IRS Audits, Collections and International Compliance Panelist, Orange County California Society of Tax Consultants (2015)
- Appeals, Collections, OIC, & Offshore Voluntary Disclosure Program IRS & FTB Issues Panelist, California Society of Tax Consultants (2014)
- 2013 Panelist IRS Audit Red Flags, California Audit & Collection Issues – CSEA San Diego Chapter