CDTFA Audit Appeals & Petitions – CPA-Led Representation Across California
If you received a CDTFA Notice of Determination or disagree with the proposed audit findings, you still have options — but your deadlines are strict. We help California business owners challenge inflated assessments through formal petitions, appeals, and settlement negotiations.
When the CDTFA’s Audit Findings Are Wrong — You Can Fight Back
CDTFA audit findings are not final. If the auditor used flawed assumptions, unrealistic markups, bad sampling periods, or incomplete information, you have the legal right to challenge their conclusions. The petition process exists precisely because CDTFA assessments are often overstated.
The key is filing a timely petition — and presenting a strong, CPA-backed defense that corrects the CDTFA’s methodology, calculations, and interpretation of your records.
Understanding the CDTFA Notice of Determination
A Notice of Determination (NOD) is one of the most serious documents CDTFA issues. It represents CDTFA’s official position on how much they believe you owe in tax, penalties, and interest. If unchallenged, it becomes final and fully enforceable — including liens, levies, and collections.
If you’ve already received an NOD, review our guidance on how to respond properly: how to respond to a CDTFA Notice of Determination.
You typically have only 30 days to file a petition.
Missing the deadline dramatically reduces your options — and CDTFA can move directly into collections.
The CDTFA Petition Process – What It Involves
A petition challenges CDTFA’s audit findings and requires a detailed explanation of where CDTFA’s conclusions are incorrect. We prepare petitions that are backed by reconstructed records, recalculated figures, corrected markup percentages, and CPA-level analysis.
A strong petition includes:
- Identification of CDTFA’s flawed methods
- Corrections to sampling, markups, or credit card ratios
- Rebuilt sales and purchase data
- Documentation of exempt or non-taxable transactions
- Evidence CDTFA misinterpreted or ignored
- A clear alternative calculation supported by CPA analysis
For deeper audit-process context, see our guide on the California sales tax audit process.
CDTFA Appeals – What Happens After You File a Petition
If CDTFA disagrees with your petition, the case may move to the Appeals Bureau or the California Office of Tax Appeals (OTA). This is an administrative legal process, but most disputes are still resolved without needing full hearings — especially when supported by expert CPA analysis and accurate recalculations.
During the appeals process, we:
- Prepare detailed position statements
- Correct CDTFA’s assumptions and audit methods
- Present reconstructed documentation
- Communicate directly with Appeals Bureau staff
- Represent you during settlement discussions
- Escalate to OTA when appropriate
Our articles on disputing CDTFA findings and appealing CDTFA audit assessments offer further insight into how these cases unfold.
Settlements & Negotiated Resolutions
Not every case needs to go to a formal appeal. Many CDTFA disputes can be resolved through settlement negotiations when we can demonstrate:
- Documented hardship
- Errors in CDTFA’s calculations
- Overstated markups or profit assumptions
- Mistakes in sampling or methodology
- Valid exemptions CDTFA overlooked
For additional guidance, read can you settle CDTFA tax debt in California.
Don’t Miss Your Deadline — Preserve Your Rights
CDTFA deadlines are strict. If you fail to petition on time, CDTFA will finalize the liability and may begin enforced collections. Contact us before the clock runs out — early representation gives you the strongest position.