Why Miami Businesses Trust Us With Sales Tax Matters

Most sales tax issues never need to reach a courtroom. They start with a notice, an audit, or a question about how a transaction should be taxed, and they're often resolved through careful recordkeeping, well-supported exemption documentation, and direct negotiation with the DOR. We help Miami businesses manage that process from the very beginning, so problems are caught early and resolved with the least cost and disruption possible.

Our attorneys and CPAs focus exclusively on Florida tax controversy, not IRS debt work or general civil practice. That narrow focus means we understand the audit and assessment patterns common to Miami, including tourism-driven sales tax exposure, international trade and customs-adjacent transactions, and high-volume hospitality and restaurant audits, and we can apply that knowledge whether your matter stays at the audit level or eventually requires a more formal response.

Attorney-CPA Team With Former DOR Auditors

Several of our partners are both attorneys and licensed CPAs. This dual background allows us to review your records with the depth of an accounting professional and translate that review into clear, practical guidance, whether you're responding to a routine audit notice, organizing exemption certificates, or deciding how to structure a transaction. We understand how your general ledger, point-of-sale system, and documentation will look to a DOR auditor, whether you operate a single Miami location or a multi-property hospitality group.

We also have former sales tax auditors on our team who understand DOR audit methodology from the inside. That perspective helps us anticipate sampling techniques, projection methods, and common error patterns, and address them early, often before they harden into a formal assessment.

Local Knowledge, Statewide Resources

Many tax resolution companies that advertise to Miami businesses focus primarily on IRS collection matters and are based outside Florida entirely. Our firm is Florida-based, with a Miami-area presence and additional offices in Fort Lauderdale, Tampa, and Tallahassee, and our practice centers on Florida tax controversy. We work within the specific procedures of the Florida Department of Revenue every day, including DOR's South Florida audit offices that frequently handle Miami-Dade examinations.

Because we are immersed in Florida tax law, we stay current on statutory changes, administrative rules, and DOR policy shifts that affect how sales tax matters are audited, resolved, and, in less common cases, litigated.

Trusted Partner to Miami CPAs and Law Firms

CPA firms and other law firms throughout Miami and South Florida frequently refer clients to us for sales tax questions that fall outside their usual scope, whether that's a complex exemption issue, an audit response, or a DOR notice that needs a prompt answer. We work collaboratively with referring professionals, supplying Florida sales tax knowledge while they continue to handle ongoing compliance, planning, or other legal needs.

This collaborative model gives Miami clients a coordinated team: their existing advisors maintain continuity on the business and federal issues, while we focus on the Florida sales tax matter at hand.

Scope of Our Miami Sales Tax Representation

We represent Miami businesses and individuals across the full range of sales tax matters, not just disputes that have escalated into formal proceedings.

Day-to-Day Compliance and Planning

Many engagements never involve an audit at all. We advise Miami businesses on taxability questions, exemption certificate management, nexus issues, and how to structure transactions to comply with Florida sales and use tax law from the outset. Getting this right reduces audit risk and strengthens your position if a question ever arises later.

Audit Notices and Audit Defense

The process often starts with a Form DR-840 Notice of Intent to Audit Books and Records. We advise Miami clients from this first contact, helping to manage document production, communications with the auditor, and the development of factual and legal positions. Most of our work happens at this stage, where careful preparation and a clear record can prevent a dispute from escalating further.

Notices of Proposed Assessment and Protests

If the DOR issues a Notice of Proposed Assessment (NOPA), we prepare and file written protests and handle negotiations aimed at reducing or eliminating improper tax, penalties, and interest. A written protest must typically be filed within 60 days of receiving a NOPA. Filing on time is critical because a timely protest generally halts collection while the matter is resolved. The large majority of NOPA disputes we handle are resolved at this protest and negotiation stage, without the need for formal litigation.

When Formal Proceedings Become Necessary

In the smaller number of cases where informal resolution isn't possible, we're fully prepared to represent clients before the Division of Administrative Hearings (DOAH) or in Florida Circuit Court, including Miami-Dade's Eleventh Judicial Circuit, and through any necessary appeal. But we approach every matter with the goal of resolving it as early and efficiently as possible, and most of our Miami clients never need to reach that stage.

Types of Miami Sales Tax Matters We Handle

• Sales and use tax compliance and planning: Helping Miami businesses get taxability, exemptions, and recordkeeping right from the start.
• Audit response and audit defense: Managing the process from the first notice through audit completion.
• Notice of Proposed Assessment protests: Challenging DOR assessments and proposed penalties.
• Penalty and interest negotiations: Working to reduce or remove additions to tax where possible.
• Voluntary disclosure: Helping businesses that discover past compliance gaps come forward on favorable terms.
• Reverse tax audits: Identifying and pursuing refunds where sales or use tax has been overpaid, a common issue for Miami hospitality and retail operations with complex exemption profiles.
• Revocation hearings: Defending against revocation of sales tax registrations and related licenses.
• Tax warrant and collection issues: Responding to liens, levies, bank freezes, and other enforcement before they escalate.
• Multistate tax questions with a Florida component: Handling matters that involve Florida alongside other states, often relevant to Miami's international and cross-border business community.
• Litigation, when necessary: Representing clients at DOAH, in circuit court, and on appeal when a matter can't be resolved informally.

We can step in at any stage, whether you're just starting to think about an exemption question, have received your first audit notice, or are already deep into a dispute.

How a Florida Sales Tax Matter Typically Unfolds

Most Florida sales tax matters follow a similar arc: a compliance question or audit notice, document review and response, and then either resolution or, if needed, a more formal protest. Litigation is the exception, not the rule, and the work we do earlier in the process is usually what determines whether it's needed at all.

Audits and Informal Resolution

During an audit, DOR examiners review returns, bank records, and sales documentation. If they believe additional tax is due, they issue a Notice of Proposed Assessment. At that point, the taxpayer can file an informal protest and request a conference or reconsideration within defined deadlines. A well-prepared response at this stage resolves the great majority of cases.

When a Dispute Moves Further

If informal avenues don't resolve the matter, it can move into more formal proceedings, either at DOAH or, in some cases, Florida Circuit Court. We advise clients on which forum fits their situation, but our priority throughout is to find the most direct path to resolution, reserving formal litigation for the matters that genuinely require it.

Why Early Engagement Matters

The DOR can employ tools such as Collection Analytics, a predictive behavioral model that helps identify and flag accounts for collection action. Engaging counsel early, ideally as soon as you receive an audit notice or have a compliance question, gives you the most room to resolve issues efficiently, avoid missed deadlines, and protect your Miami business operations, bank accounts, and cash flow.

Frequently Asked Questions About Florida Sales Tax Representation

Do I Need a Lawyer Just to Respond to an Audit Notice?

Not necessarily, but early advice often prevents bigger problems. Many Miami businesses bring us in at the audit notice stage specifically to avoid an assessment in the first place, by helping organize records, respond to information requests, and frame the factual story for the auditor before positions become fixed.

What's the Difference Between a Protest and Litigation?

A protest is an informal, internal DOR process for challenging a proposed assessment, typically resolved through negotiation and conference rather than a courtroom. Litigation, at DOAH or in circuit court, is a more formal process with its own procedural rules, used only when informal resolution isn't possible. The large majority of Florida sales tax matters are resolved through audit defense or protest, without ever requiring litigation.

Can a Sales Tax Issue Be Resolved Without Going to DOAH?

Yes, and most are. Many matters resolve at the audit stage or through the informal protest process, often with reduced or eliminated penalties and interest. We focus on resolving matters as early as possible and only pursue formal proceedings when that's genuinely the best path for the client.

Can CPAs or Other Accounting Professionals Handle Sales Tax Matters on Their Own?

CPAs and other accounting professionals play an important role in preparing records, reconstructing transactions, and advising on compliance, and many matters can be handled with that support alone. However, once a matter involves legal interpretation, formal protest strategy, or representation before the DOR in a contested matter, only licensed Florida attorneys can provide legal representation. We often work alongside Miami CPAs to combine accounting depth with legal guidance.

What Should I Do If I Receive a DOR Audit Notice?

Respond promptly and avoid providing documents or statements without first understanding how they may be used. Even if you don't yet need full representation, an initial consultation can help you understand the scope of the audit and how to respond in a way that protects your position.

If you have a Florida sales or use tax question, whether it's a compliance matter, an audit notice, or an active dispute, contact Law Offices of Moffa, Sutton, & Donnini, P.A. at (888) 444-9568 to speak with our Florida tax controversy team.