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Jason M. Silver has been helping clients solve serious tax problems for more than 30 years. Before joining Silver Law, he worked as a trial attorney for the IRS, giving him a clear understanding of how the agency works and what it takes to get results. Jason helps with everything from audits and collections to tax investigations and court cases. He’s a certified tax law specialist in Arizona and has handled cases at both the state and federal level. Clients appreciate his calm approach, deep knowledge, and strong focus on getting them the best possible outcome.

Areas of Practice
Certified Legal Specialties
Bar Admissions
Education
Published Works
Representative Cases
Classes/Seminars
Honors and Awards
Professional Associations and Memberships
Past Employment Positions

Areas of Practice

Active administrative tax practice dealing with local, state and federal audits, collections and criminal investigations
Civil and criminal tax litigation in all federal and State of Arizona Courts and appeals therefrom, civil litigation in the United States Tax Court, Federal District Court and the United States Court of Federal Claims
Arizona Accounting Board representation
Expert witness testimony
Entity formations
White Collar Criminal Litigation

Certified Legal Specialties

Tax Law Specialist, Board of Legal Specialization of the State Bar of Arizona

Bar Admissions

Arizona, 1995
California, 1997
U.S. District Court Central District of California, 1999
U.S. District Court Eastern District of California, 2006
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, 2002
U.S. District Court District of New Mexico, 2022
U.S. District Court District of Colorado, 2022
U.S. Court of Appeals 9th Circuit, 1996
U.S. Court of Appeals Federal Circuit, 2023
U.S. Court of Appeals 10th Circuit, 2023
U.S. Court of Federal Claims, 2008
U.S. Tax Court, 1995
U.S. Supreme Court, 2007

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

Form 8300 and your Car Dealership’s Reporting Requirements
Why Innocent Spouse Relief Should be Considered in Divorce, June 2003
The New Tax Law Burden of Proof and Production, May 2002
A Kinder, Gentler IRS, The Federal Tax Lawyer, assisted in preparation of the article (November/December, 1999)

Representative Cases

Classes/Seminars

Presenter: COVID Tax Relief Fraud Enforcement, Arizona Forum for Improvement of Taxation, January 27, 2023
Presenter: IRS and other initiatives in COVID relief (PPP, Employee Retention Credit, Economic Injury Disaster Loans) fraud investigations, along with an increasing number of IRS referrals for criminal prosecution of non-payment of payroll trust fund taxes, Southwest Fest Enrolled Agents, June 16, 2022
Presenter: IRS Initiatives: High-Income Taxpayers, Arizona Forum for Improvement of Taxation, January 20, 2022
Presenter: Community Property, Arizona Forum for Improvement of Taxation, January 22, 2021
Presenter: Cryptocurrency, Arizona Forum for Improvement of Taxation, January 23, 2020
Presenter: State of Arizona Criminal Tax Issues, Phoenix Tax Workshop, November 16, 2019
Presenter: FBAR’s and Foreign Transactions, Arizona Society of Enrolled Agents, October 17, 2019
Presenter: IRS Audit Reconsideration vs. IRS Offer in Compromise Based upon Doubt as to Liability, Arizona Forum for Improvement of Taxation, July 25, 2019
Presenter: IRS Criminal Enforcement Priorities, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, January 25, 2018
Presenter: FBAR and Other Foreign Disclosure Requirements, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, January 19, 2017
Presenter: Conflicts of Interest for Tax Professionals, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, July 21, 2016
Presenter: Where Did the Money Go, and How Will the Government Find it?, American Bar Association, December 14, 2014
Presenter: Form 8300 and Your Reporting Requirements/Avoiding Unintentional “Structuring” of Cash Transactions, Arizona Forum for Improvement of Taxation, July 16, 2014
Presenter: IRS Audits, Arizona Society of Practicing Accountants, East Valley Chapter, August 13, 2013
Presenter: Worker Classification Issues and Solutions for Employers, January 2013, Arizonans Forum Improvement of Taxation
Presenter: Tax Issues in a Down Economy, State Bar of Arizona Convention, 2012
Presenter: The Changing Landscape of Tax Law, Ethics and Professional Responsibility, State Bar of Arizona Convention, 2011
Presenter: Anatomy of an IRS Field Examination: From Initial Audit Notification to Appeals, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, July 21, 2010
Presenter: 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
Presenter: Indirect Methods of Proof, Arizona Forum for Improvement of Taxation, 2009
Presenter: ADOR Tax Amnesty and IRS Invited Taxpayers to Disclose Offshore Account; Offer Penalty Abatement, Phoenix Tax Workshop, 2009
Presenter: Tax Collection Enforcement, Arizona State Bar Association, Convention, 2008
Presenter: Tax Procedure in Collection Cases, Entrepreneurial CPA Network, 2008
Presenter: Discussion of Current Developments: Update on Federal Offers in Compromise, Phoenix Tax Workshop, 2008
Presenter: Unexpected Tax Consequences: Residential Foreclosures and Short-Sales as Forgiveness of Debt, Arizona State Bar Bankruptcy Section, 2008
Presenter: Federal Trust Fund Taxes, State Bar of Arizona, Presenter, 2007
Presenter: New IRS Fraud Guidelines in Civil Audits, Phoenix Tax Workshop, 2006
Presenter: Disregarded Entity or Elect to be Taxed as a S Corporation. Election, Is this the new Planning Vehicle?, Phoenix Tax Workshop, 2004
Presenter: What to do when you are faced with a Trust Fund (Payroll) Tax Assessment, including Trust Fund Recovery Penalty Interview, Defense and Case Law, Phoenix Tax Workshop, 2004
Presenter: Effective Tax Planning and Litigation Using IRS Guidance, State Bar of Arizona Seminar, Moderator, 2003
Presenter: ADOR Amnesty Program to Help Close the Budget Gap?, Phoenix Tax Workshop, 2003
Presenter: Tax Disputes from Cradle to Grave, State Bar of Arizona Convention, Moderator, 2003
Presenter: Settling Tax Disputes with the IRS – Is Mediation the Answer?, Phoenix Tax Workshop, 2002
Presenter: Offers in Compromise and What to Do When the IRS Knocks on Your Door, Arizona Society of Practicing Accountants, 2002
Presenter: Offers in Compromise, Phoenix Tax Workshop, 2002
Presenter: The New Tax Court Burden of Proof, A Dangerous Placebo?, Phoenix Tax Workshop, 2001
Presenter: Criminal Forfeitures, Presented to Criminal Investigation Special Agents, 1999
Presenter: How to Effectively Audit a Retail Gasoline Station, Presented to specialty group of IRS Revenue Agents, 1997 – 1999
Presenter: The Tax Audit of a Civil Capper Case, Presented to special group of IRS Revenue Agents, 1998

Honors and Awards

Fellow, American College of Tax Counsel
Best Lawyers in America
Top Arizona Attorneys in Arizona, Arizona Magazine, May 2012
Southwest Super Lawyers
Martindale Hubbell AV Rated
North Valley Magazine Top Lawyers in Tax, October/November 2011
U.S. News-Best Lawyers, “Best Law Firm” Rankings, Tax Litigation and Tax Law, Tier 1

Professional Associations and Memberships

California Bar Association
Phoenix Tax Workshop, Advisory Board, 2002 – Present
United States Tax Court Judicial Conference, Lawyer Representative
Arizona State Bar, Tax Section, Chairman, 2010 – 2011
Arizona State Bar, Tax Section, Program Coordinator
Arizona State Bar, Tax Section, Member at Large
Arizona State Bar, Tax Section, Secretary
Arizona State Bar, Tax Section, Vice President
Arizona State Bar, Tax Section, Chair Elect
Arizona Forum for the Improvement of Taxation, Board Member, Vice President, 2012 – 2018, President 2018 – Present

Past Employment Positions

Kajan, Mather and Barish, A Professional Corporation, Associate, Beverly Hills, California, 1999 – 2000
Office of Chief Counsel, Internal Revenue Service, Trial Attorney and Criminal Tax Attorney, Los Angeles, California, 1995 – 1999

Members Page – Test

Jason M. Silver