Jason M. Silver
Member since 2001
Areas of Practice
- Active administrative tax practice dealing with local, state and federal audits
- and criminal investigations, civil and criminal litigation in the Arizona Court
- and appeals therefrom, civi litigation in the United States Tax Court and
- Federal District Court, expert witness testimony, business planning,
- estate planning, probate, and entity formations.
Certified Legal Specialties
- Tax Law Specialist, The Board of Legal Specialization of the State Bar of Arizona, 2007
Bar Admissions
- Arizona, 1995
- California, 1997
- U.S. District Court Eastern District of California, 2006
- U.S. District Court Central District of California, 1999
- U.S. District Court Southern District of California, 2007
- U.S. District Court Northern District of California, 2007
- U.S. District Court District of Arizona, 2007
- U.S. Tax Court, 1995
- U.S. Court of Federal Claims, 2008
- U.S. Court of Appeals 9th Circuit, 1996
- U.S. Supreme Court, 2008
Education
- Gonzaga University School of Law, Spokane, Washington
- J.D. - May, 1995
- University of Arizona, Tucson, Arizona
- B.S. - May, 1992
- Major: Accounting
Published Works
- Why Innocent Spouse Relief Should be Considered in Divorce, Family Law News, State of Arizona (June, 2003)
- The New Tax Court Burden of Proof and Production, Tax News, Newsletter of the Tax Section of the State Bar of Arizona (May, 2002)
- A Kinder, Gentler IRS, The Federal Tax Lawyer, assisted in preparation of the article (November/December, 1999)
Representative Cases
- City of Mesa v. Val-Pak East Valley, Inc., 1 CA-TX 08-0010 (Arizona Court of Appeals 2010)
- FRGC Investment, LLC v. Commissioner, T.C. Memo. 2002-276 (U.S. Tax Court 2002)
- Chamales v. Commissioner, T.C. Memo. 2000-33 (U.S. Tax Court 2000)
- Brewer v. Commissioner, T.C. Memo. 1997-543 (U.S. Tax Court 1999)
- Wilson v. Commissioner, T.C. Memo. 1999-327 (U.S. Tax Court 1999)
- Paig v. Commissioner, T.C. Summary Opinion 1999-47 (U.S. Tax Court 1999)
- Berge v. Commissioner, T.C. Summary Opinion 1999-41 (U.S. Tax Court 1999)
- Steppes v. Commissioner, T.C. Summary Opinion 1998-208 (U.S. Tax Court 1998)
- Guerrero v. Commissioner, T.C. Memo. 1998-221 (U.S. Tax Court 1998)
- Bushey v. Commissioner, T.C. Summary Opinion 1998-150 (U.S. Tax Court 1998)
- Guarna v. Commissioner, T.C. Summary Opinion 1998-94 (U.S. Tax Court 1998)
- Boatner v. Commissioner, T.C. Memo. 1997-379 (9th Cir. 1998)
- Boatner v. Commissioner, aff'd, 164 F.3d 629 (U.S. Tax Court 1997)
- Chiu v. Commissioner, T.C. Memo. 1997-199 (U.S. Tax Court 1996)
- Levin v. Commissioner, T.C. Memo. 1996-211 (U.S. Tax Court 1996)
- Conrad v. Commissioner, T.C. Summary Opinion 1996-194 (U.S. Tax Court 1996)
- Capka v. Commissioner, T.C. Summary Opinion 1996-194 (U.S. Tax Court 1996)
- Barnhill v. Commissioner, T.C. Memo. 1996-97 (U.S. Tax Court 1996)
Classes/Seminars
- Is Out of State Job Printing Subject to Use Tax? Voluntarily Disclosing Foreign Bank Accounts. Is it safe to do so if you did not file under the IRS Settlement Initiative?, Entrepreneurial CPA Network Meeting, 2010
- Indirect Methods of Proof, Arizonans for the Improvement of Taxation, 2009
- ADOR Tax Amenesty and IRS Invited Taxpayers to Disclose Offshore Account; Offer Penalty Abatement, Phoenix Tax Workshop, 2009
- Tax Collection Enforcement, Arizona State Bar Association, Convention, 2008
- Tax Procedure in Collection Cases, Entrepreneurial CPA Network, 2008
- Discussion of Current Developments: Update on Federal Offers in Compromise, Phoenix Tax Workshop, 2008
- Unexpected Tax Consequences: Residential Foreclosures and Short-Sales as Forgiveness of Debt, Arizona State Bar Bankruptcy Section, 2008
- Federal Trust Fund Taxes, State Bar of Arizona, Presenter, 2007
- New IRS Fraud Guidelines in Civil Audits, Phoenix Tax Workshop, 2006
- Disregarded Entity or Elect to be Taxed as a S Corporation. Election, Is this the new Planning Vehicle?, Phoenix Tax Workshp, 2004
- What to do when you are faced with a Trust Fund (Payroll) Tax Assessment, including Trust Fund Recovery Penatly Interview, Defense and Case Law, Phoenix Tax Workshop, 2004
- Effective Tax Planing and Litigation Using IRS Guidance, State Bar of Arizona Seminar, Moderator, 2003
- ADOR Amenesty Program to Help Close the Budget Gap?, Phoenix Tax Workshop, 2003
- Tax Disputes from Cradle to Grave, State Bar of Arizona Convention, Moderator, 2003
- Settling Tax Disputes with the IRS - Is Mediation the Answer?, Phoenix Tax Workshop, 2002
- Offers in Compromise and What to Do When the IRS Knocks on Your Door, Arizona Society of Practicing Accountants, 2002
- Offers in Compromise, Phoenix Tax Workshop, 2002
- The New Tax Court Burden of Proof, A Dangerous Placebo?, Phoenix Tax Workshop, 2001
- Criminal Forfeitures, Presented to Criminal Investigation Special Agents, 1999
- How to Effectively Audit a Retail Gasoline Station, Presented to specialty group of IRS Revenue Agents, 1997 - 1999
- The Tax Audit of a Civil Capper Case, Presented to special group of IRS Revenue Agents, 1998
Honors and Awards
- Martindale Hubbell AV Rated
Professional Associations and Memberships
- American Bar Association
- Arizona Bar Association, Chairman for Tax Section of State Bar of Arizona, June 1, 2010 - Present
- California Bar Association
- Phoenix Tax Workshop, Advisory Board, 2002 - Present
- United States Tax Court Judicial Conference, Lawyer Representative
Past Employment Positions
- Kajan, Mather and Barish, A Professional Corporation, Associate, 1999 - 2000
- Office of Chief Counsel, Internal Revenue Service, Trial Attorney, 1995 - 1999