Tax & IRS
The tax practice of Silverman Thompson tracks the rapidly-changing tax laws and IRS regulations in order to provide the best legal representation possible to help you resolve various civil and criminal tax matters, ranging from IRS penalty notices, to voluntary offshore disclosures.
We handle a variety of civil tax issues, including constructive dividends, currently not collectible status, independent contractor disputes, innocent spouse tax relief, installment agreements, IRS liens and levies, IRS summons, offers in compromise, and payroll tax liabilities. Regardless of the issue, we ensure our clients receive due process, offering representation through IRS appeal procedures, and negotiating the best outcome for our client.
Criminally, our department, headed by an attorney with seven years’ experience with the Criminal Tax division of the IRS Office of Chief Counsel, has the specialized expertise and knowledge necessary to advise on criminal tax matters, including employment tax fraud, failure to file information and/or tax returns, filing false tax returns, foreign gift and trust reporting, good faith defenses, offshore account voluntary disclosures, structuring violations, and tax evasion.
Specifically, our services include:
- Guidance and assistance in preparing for federal audits
- Successful representation for income, franchise, sales and use, payroll, earned income, and privilege tax audits
- Evaluation and identification of areas of audit exposure and preparation for audits, including reviewing audit issues, the steps involved and representation during the audit process
- Settlement negotiations with field agents
- Assistance with determining eligibility for offers-in-compromise or installment payment plans
- Correspondence with the IRS, or other tax authorities, in response to notices
- Documentation of supporting tax law via memorandum or opinion letter
- Isolation of the audit process through utilization of our offices
- Assistance with data collection and calculations
- Complete, effective and efficient representation from assessment to appeals
- Responding to civil injunctions for tax preparers
- Coordination with/referral to certified public accountants for technical issues
- Assistance with federal tax liens
- Assistance with levies on property and wages, bank accounts and retirement
- Preparation and negotiation of voluntary disclosure agreements
- Defense of criminal failure to file cases
- Defense of criminal tax evasion cases, including charges of hidden and unreported assets domestically or overseas, failure to pay over payroll tax, and/or using abusive trusts to conceal income
- Compliance with Foreign Bank Account Reporting (FBAR) Requirements
- Representation through the appellate process, both civilly and criminally
Our tax attorneys understand that professional communication and establishing rapport with IRS agents is crucial to resolving tax matters. They are familiar with the IRS and strive to protect their clients’ rights while providing efficient, excellent expertise to resolve tax disputes.