OUR CRIMINAL TAX LITIGATION EXPERIENCE

The Criminal Tax Experience You Need to Keep Your Business
In the Office and Out of the Courtroom

<li>Obtained the acquittal on charges of income tax evasion of a dentist characterized as a tax protester by the IRS who held a good faith belief that he had a constitutional right not to provide information concerning his income on returns he filed, and displayed sincere contrition that he had been misled.</li>
Our attorneys at Silver Law PLC have represented corporations who are targets, subjects or witnesses in IRS investigations. We do so skillfully and discreetly, often resolving issues during the investigation instead of litigation.

Examples of our criminal tax practice include:

Obtaining a permanent injunction from the United States District Court which enjoined a criminal investigation of a lawyer conducted in the guise of a civil tax audit and, on appeal to the Ninth Circuit Court of Appeals, the suppression of all evidence and leads therefrom illegally gathered by the IRS.

Obtaining an injunction from the United States District Court, suppressing evidence seized by IRS agents in an undercover investigation of a local business owner conducted as part of a national business opportunities sting operation.

Obtained a judgment of acquittal for a doctor tried on charges of filing false personal income tax returns.

Obtained the return of three million dollars and other property seized by the IRS and other federal agents under an Internal Revenue Code section authorizing the forfeiture of property used or intended to be used in violating the internal revenue laws after litigating in two different states.

Representing a foreign national residing in the United States before a federal grand jury seeking a written consent to the disclosure of alleged foreign bank records otherwise protected by the laws of the foreign sovereign and in a subsequent contempt proceeding before the United States District Court, the Ninth Circuit Court of Appeals and the United States Supreme Court.

Obtained the acquittal on charges of income tax evasion of a dentist characterized as a tax protester by the IRS who held a good faith belief that he had a constitutional right not to provide information concerning his income on returns he filed, and displayed sincere contrition that he had been misled.

Negotiating a plea to the misdemeanor of failing to supply information in return for the dismissal of conspiracy and tax evasion charges against a businessman involved in a complex international insurance and loan transaction.

Acting as amicus curiae in obtaining a new trial for a husband and wife convicted in a failure to file case where the state court denied the taxpayers the opportunity to present a good-faith defense.

Obtained a judgment of acquittal for a CPA who when contacted by criminal investigators from the Arizona Department of Revenue had not filed state income tax returns and was subsequently charged with four class two scheme and artifice to defraud felonies and four class five falsifying income tax return felonies which related to allegedly claiming false tax deductions over a four-year period in excess of a half million dollars; in the civil audit to follow, the agreed-upon tax liability without any penalties was less than $2,500 for the four-year period.

Negotiated a plea to a one count misdemeanor of failing to supply information in lieu of felony charges for two years of tax evasion and filing false returns against dentist.

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