Experienced Tax Lawyers in Scottsdale Serving the Greater Phoenix Area
Tax Litigation • Tax Audit Representation • Collections • Innocent Spouse Relief
At the office of Silver Law PLC, in Scottsdale, Arizona, we have more than 80 years of combined experience protecting the rights of individuals and businesses involved in tax controversies. Because all of our attorneys formerly worked for the Internal Revenue Service, we have a comprehensive understanding of both sides of a tax dispute. We know how tax authorities handle different types of issues and will use our knowledge and skill to protect your interests.
Our Tax Law Experience
Our Tax Attorney Services
Tax Litigation. We represent individuals and business in disputes involving tax liability, including civil and criminal matters. We will protect you at all stages of a civil or criminal tax dispute, from the grand jury administrative proceeding through court appeals.
Tax Audit Representation. We work with individuals or businesses throughout the audit process, whether you have just received notice of an impending audit or would like to appeal the findings of a recently completed audit.
Tax Collections. We protect the rights of individuals and businesses facing tax collection efforts, helping you negotiate an offer in compromise or an installment payment plan, whenever possible, or defend against an attempt to place a lien or levy on your property. We also handle tax collection efforts involving employment taxes, such as withholding, FICA, Social Security and sales tax.
Innocent Spouse Relief. We assist spouses who face tax assessments, fines or penalties because of wrongful or illegal acts by their spouses or former spouses.
Foreign Tax reporting/Offshore Voluntary Disclosure Initiative. We will work with you on your foreign reporting requirements, including reporting foreign bank account, trusts, corporations and property holdings. Also, we will assist you in disclosing to the Internal Revenue Service previously undisclosed foreign bank account under the current Offshore Voluntary Disclosure Initiative.
On March 1, 2012: The U.S. Tax Court held in Slone, transferee, et al., T.C. Memo. 2012-57, for the taxpayers. The IRS had proposed a tax of $16,193,881, a penalty of $2,550,832 and accrued interest, bringing the total balance to almost $25 million. The U.S. Tax Court determined that the issue at hand was whether the IRS had shown that the substance of the stock sale and not the form, gave rise to transferee liability. After analyzing the facts, the U.S. Tax Court held that neither the substance over form doctrine, nor any related doctrines apply to recast the stock sale as a liquidating distribution and therefore, the Court held that the stock sale should be respected for Federal tax purposes.
On April 19, 2016: In captive insurance audit, the Court finds that the IRS cannot Enforce a Summons compelling a taxpayer to testify when he properly invokes his Fifth Amendment Privilege against compelled self-incrimination.