Legal Division

The Legal Division is comprised of the Appeals Bureau, Litigation Bureau, Tax and Fee Programs Bureau, and Settlement and Taxpayer Services Bureau. The members of the Division provide advice to taxpayers and to the California Department of Tax and Fee Administration staff. The members of the Division also work on a variety of areas, including legislation, regulations, litigation, subpoenas, administrative tax appeals, settlements, offers in compromise, criminal tax evasion and fraud matters, bankruptcy, tax controversy, and personnel matters.

Chris Schutz, Chief Counsel
Adrianne Richardson, Administrative Assistant, 1-916-309-0639

If you would like to report suspected sales, fuel or cigarette and tobacco products tax evasion, contact the California Department of Tax and Fee Administration, Investigations Bureau at 1-916-324-0105 or the Tax Evasion Hotline at 1-888-334-3300.


The Appeals Bureau serves as the final level of review for the California Department of Tax and Fee Administration on appeals filed by taxpayers contesting business and special tax liabilities and/or local and district tax reallocations. The Appeals Bureau holds conferences to provide the taxpayers and the Business Tax and Fee Division an opportunity to set forth their contentions and provide additional information in support of their positions. At the conclusion of the information gathering stage, the Appeals Bureau issues an independent and impartial decision to address the facts and law presented in the case. Taxpayers who disagree with the Appeals Bureau's decision may request review of the decision by the Office of Tax Appeals.

Jefferson Vest, Assistant Chief Counsel
Shannon Haefner, Executive Assistant 1-916-616-0659

Michelle Albright, Supervisor 916-210-9757

Casey Tichy, Supervisor 916-539-4989

Quan Vuong, Supervisor 562-379-9749


Wendy Vierra, Assistant Chief Counsel, 916-309-8326
Tamara Hupp, Supervisor, 916-309-8333

The Litigation Bureau – Tax and Fee Litigation Section advises and represents the Department in litigation involving the taxes and fees that the Department collects. The Litigation Bureau – Administrative Programs Section represents the Department in litigation and administrative proceedings involving employment, labor, and civil rights matters. The Litigation Bureau – Bankruptcy and Collections Section advises and represents the Department in bankruptcy proceedings and state court collection litigation. The Litigation Bureau – Subpoena Section processes the Department's incoming and outgoing subpoenas.

Tax and Fee Litigation Section

Wendy Vierra, 916-309-8326

Administrative Programs Section

Kimberly Willy, 916-309-8320

Bankruptcy and Collections Section

Victoria C. Geary, 916-309-8327

Subpoena Section

Tamara Hupp, 916-309-8333

Settlement and Taxpayer Services

The Settlement and Taxpayer Services Bureau administers the Department's Administrative Settlement Program. Under this program, staff negotiate settlements of certain Sales and Use Tax and Special Tax and Fee cases consistent with a reasonable evaluation of the risks and costs of litigating those cases. To be eligible for this program, cases must be the subject of an appeal, protest or claim for refund. Additionally, the Bureau's Offers in Compromise Section considers and processes offers to compromise undisputed final tax or fee liabilities and requests for relief of liability under the Innocent Spouse and Equitable Relief provisions of the Revenue and Taxation Code. The Bureau also provides legal oversight and support on contract matters, responds to Public Records Act and Information Practices Act requests, as well as Exchange of Information requests, through its Disclosure Office, and provides advice on issues such as ethics and general conflict of interest-related issues, financial conflicts of interest under the Political Reform Act (including Conflict of Interest Code and Form 700 advice), education and outreach activities, exchange/disclosure agreements, and local tax revenue and allocation matters.

Amy Kelly, Assistant Chief Counsel

Settlement 916-324-2836
Jenny Choi, Tax Counsel IV 562-379-9803
Katie Lien, Tax Counsel IV 562-379-9807

Offers in Compromise 916-322-7931
Shari Miura, Acting Supervisor 916-309-8323
Lei Anderson, Lead 916-764-2031

Tax and Fee Programs

Attorneys in the Tax and Fee Programs Bureau advise taxpayers/feepayers, taxpayer/feepayer representatives, and city, county and state officials on various legal issues involving the tax and fee programs administered by the California Department of Tax and Fee Administration (CDTFA). These programs include, but are not limited to, Sales and Use Tax, Bradley-Burns Uniform Local Sales and Use Tax, Transactions and Use (District) Tax, Cigarette and Tobacco Products Tax, Cigarette and Tobacco Products Licensing, Cannabis Tax, Motor Vehicle Fuel Tax, Jet Fuel Tax, Underground Storage Tank Maintenance Fee, Use Fuel Tax, Diesel Fuel Tax, Oil Spill Response Prevention and Administration Fees, Energy Resources Surcharge, Emergency Telephone Users Surcharge, Prepaid Mobile Telephony Services Surcharge, Fire Prevention Fee, Hazardous Substances Taxes and Fees, Childhood Lead Poisoning Prevention Fee, Occupational Lead Poisoning Prevention Fee, Integrated Waste Management Fee, Lead-Acid Battery Fee, Lumber Products Assessment, California Tire Fee, Marine Invasive Species Fee, Natural Gas Surcharge, Covered Electronic Waste Recycling Fee, and Water Rights Fee. Attorneys in the Tax and Fee Programs Bureau also represent CDTFA in administrative hearings, help draft regulatory changes, and provide legal oversight and support to the Investigations Bureau on matters involving tax evasion and fraud, including criminal tax law matters and implementation of the Cigarette and Tobacco Products Licensing Act of 2003.

Members of the public may request a legal opinion on tax and fee matters by submitting a request in writing. The specific facts and circumstances of the activity or transaction at issue should be fully described in the request for advice, as well as the question on those facts. Requests for advice should be submitted to: Ms. Pamela Bergin, Assistant Chief Counsel, Tax and Fee Programs Bureau (MIC:82); California Department of Tax and Fee Administration; 450 N Street, P.O. Box 942879, Sacramento, CA 94279-0082.

Assistant Chief Counsel
Pamela Bergin, Assistant Chief Counsel, 916-309-8336
Yuliya Wieg, Associate Governmental Program Analyst, 916-309-8345