Tax Controversy Litigation

At Silverman Thompson, we bring the same rigorous, courtroom-honed advocacy that has defined our litigation practice for decades to the complex world of tax controversy. 

When tax authorities challenge you, you need a team with deep litigation experience and an accomplished attorney who knows tax practice from both sides of the courtroom. A “simple” audit can become a complicated assessment and collection case, or even a criminal prosecution, faster than most people realize. Don’t go it alone. 

Gregory P. Bailey is a former federal prosecutor serving almost a decade in the U.S. Department of Justice Tax Division. As a federal prosecutor, Mr. Bailey worked every day in the complicated world of federal taxation laws. Spearheading investigations and leading prosecutions of individuals, non-profits, and corporate entities, Mr. Bailey gained an integral knowledge of the IRS investigation process and the facts necessary to successfully establish violations of the nation’s tax laws.  

In private practice, Mr. Bailey exploits that knowledge to the benefit of his clients in IRS administrative matters, civil enforcement cases brought by the Department of Justice, and criminal prosecutions brought throughout the United States. 

Following his service in the government, Mr. Bailey has successfully represented individuals and entities before the IRS, in the United States Tax Court, and in United States District Courts across the country.  

The Internal Revenue Service has the tools, resources, and power of the United States government on their side, you should have someone experienced at challenging them on yours. Whether you’re an individual taxpayer, a business (for-profit or nonprofit), or a professional tax return preparer, before you answer any request from the IRS (i.e., summons, request for information, subpoena, or a simple request to chat with you), you should have representation that will guide you to the best possible outcome in your case.  

Mr. Bailey and our team understand your challenges, your objectives, and have relentlessly battled the IRS on behalf of clients. We will assess the facts and circumstances of your individual situation, recommend the best course of action, and implement solutions to mitigate the tax consequences. Those solutions could include a voluntary disclosure to the IRS, a lawsuit against the federal government, or any of the other innumerable options somewhere in the middle.  

The bottom line is this: if you have recently been contacted by the IRS or you have been grappling with them alone for years, you need experienced tax litigators advocating for you and Silverman Thompson is ready to enter the fight. 

Our Tax Controversy Practice Areas 

We represent clients across a broad spectrum of tax disputes, including: 

• IRS Audits: Handling traditional exams, as well as “eggshell” audits where the IRS targets particularly vulnerable taxpayers with possible criminal implications 

• IRS Appeals 

• Penalty Abatement 

• Voluntary Disclosures 

• Tax Preparer Injunction Matters 

• Federal Litigation: Representing clients in U.S. Tax Court, federal District Court, and other venues when necessary 

• Criminal Investigations & Prosecutions 

Who We Represent 

At Silverman Thompson, Mr. Bailey and our tax controversy team represent: 

• Individual taxpayers 
• Corporate & non-profit entities 
• Professional tax return preparers  

Meet Our Team 

Gregory P. Bailey brings a unique combination of prosecutorial, military, and criminal defense experience to his tax controversy litigation practice.  

• Former U.S. Navy Officer, graduate of the U.S. Naval Academy, veteran of Operation Iraqi Freedom 

• Spent 10 years with the U.S. Department of Justice Tax Division, handling tax fraud, financial crimes, and more across 12 states 

• Worked on federal regulatory investigations in the Office of Enforcement at the Federal Energy Regulatory Commission 

• Tried numerous federal trials, handled appeals, and is equally comfortable negotiating pre-litigation resolutions 

• Recipient of the DOJ Tax Division Outstanding Attorney Award (2018–2019) and FBI Washington Field Office Service Award (2012) 

Learn more about Greg Bailey’s experience here. 

For representation inquires and consultations please contact us at 410.385.2225.