Silver Law PLC

History and growth

• Silver Law PLC has been handling tax controversy matters for more than 20 years.
• The firm has grown to include multiple offices in Arizona, California, Nevada and Utah.
• The team now includes partners, associates, enrolled agents, CPAs and paralegals with extensive backgrounds in tax law, accounting and government service.

Former IRS attorneys and tax professionals

• All of the firm's attorneys previously worked for the Internal Revenue Service as trial attorneys or in other roles.
• This prior government experience gives the team detailed insight into how the IRS approaches audits, collections, criminal investigations and litigation.
• Several professionals, including attorneys and enrolled agents, also have experience in tax preparation, accounting and financial statement work.

Courts and jurisdictions

Silver Law PLC attorneys are licensed to practice:

• In the state courts of Arizona, California, Nevada and Utah.
• In federal courts for those states.
• Before the United States Tax Court, U.S. Court of Federal Claims, the Ninth and Tenth Circuit Courts of Appeals, the Federal Circuit, and the U.S. Supreme Court.

This broad licensing allows the firm to represent clients in local, regional and nationwide tax controversies.

Recognition

• Silver Law PLC has been recognized among the Best Law Firms® 2024 by Best Lawyers® for tax litigation and controversy work.
• The firm emphasizes high‑level, personalized representation in complex civil and criminal tax matters.

Legal team

The legal team includes:

• Partners and attorneys with decades of combined tax controversy experience, including leadership roles in significant tax cases.
• Attorneys who are also CPAs, combining legal and accounting training.
• Enrolled Agents and CPAs who assist with audits, collections, financial analysis and case preparation.
• Paralegals with deep experience in tax controversy support, including captive insurance and other specialized tax issues.

Approach to client service

• Focus on tax controversy and related white collar matters only, rather than general practice.
• Representation of both individuals and businesses, from smaller disputes to large, complex cases.
• Emphasis on thorough preparation, strategic advocacy and clear communication with clients.

White collar tax crimes can lead to:

• Prison sentences for serious offenses.
• Substantial fines and potential restitution.
• Long‑term collateral consequences, such as loss of professional licenses, reputational harm, and difficulties with future employment or housing.

Can IRS penalties be reduced or removed?

In many cases, yes. The IRS offers programs that may reduce or eliminate certain penalties, including:

• First‑Time Penalty Abatement for taxpayers with a strong compliance history.
• Reasonable Cause Relief when circumstances beyond the taxpayer's control (such as serious illness or natural disasters) led to non‑compliance.

Requests are typically made by written submission (for example, using Form 843) or by phone, and unfavorable decisions may be appealed.

How long do I have to respond to an IRS audit notice?

Most IRS audit notices provide around 30 days from the date on the notice to respond, though deadlines vary depending on the type of audit or letter. Responding promptly is critical to protecting your rights and avoiding additional penalties. Extensions may be available in some circumstances.

What are common penalties for tax evasion?

Tax evasion can result in:

• Significant civil penalties and interest on unpaid taxes.
• Federal criminal penalties, which may include up to five years in prison and substantial fines (for example, up to $100,000 for individuals and $500,000 for corporations, depending on the statute involved).
• Additional state‑level penalties, which can range from misdemeanors to felonies based on the severity of the conduct.

How can a tax attorney help with complex tax disputes?

A tax attorney can:

• Analyze your situation, advise you on your rights and obligations, and help you understand your options.
• Communicate and negotiate with the IRS or state tax authorities on your behalf.
• Represent you in audits, appeals, Tax Court or other courts, and in criminal tax investigations.
• Work to minimize tax, penalties and collateral consequences where the law allows.

What types of tax controversies does Silver Law PLC handle?

Silver Law PLC handles a wide range of disputes, including:

• IRS and state audits.
• Collections matters (liens, levies, garnishments and other enforced collection actions).
• Tax litigation in Tax Court, federal courts and state courts.
• Innocent spouse and similar relief claims.
• Tax fraud and tax evasion investigations.
• Disputes over deductions, credits and reported income.
• Matters involving foreign reporting, cannabis‑industry tax issues and white collar tax crimes.

How should I prepare for an IRS audit?

Helpful steps typically include:

• Gathering and organizing relevant financial records, receipts and statements.
• Reviewing the returns under examination for accuracy and completeness.
• Preparing clear explanations and supporting documentation for large or unusual items.
• Consulting a tax attorney before responding directly to the IRS so that your rights are protected and communications are properly handled.

Can businesses negotiate settlements for unpaid taxes?

Yes. Businesses (and individuals) can often negotiate with the IRS or state tax authorities using tools such as:

• Installment agreements (payment plans).
• Offers in Compromise (where eligible).
• Penalty abatement requests.
• Requests for Currently Not Collectible (CNC) status when there is severe financial hardship.

Each option has strict eligibility and documentation requirements. Silver Law PLC assists clients in evaluating options and pursuing the relief that best fits their situation.

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This FAQ is a general summary of information drawn from Silver Law PLC's public materials and is not legal advice. For advice about a specific matter, contact the firm directly to discuss your situation.

Overview of tax controversy services

Silver Law PLC focuses exclusively on tax controversies and related white collar matters. All attorneys are former IRS lawyers, and the firm represents both individuals and businesses in disputes with the IRS and state tax authorities.

Core practice areas

Tax litigation

• Civil and criminal tax litigation in:
• U.S. Tax Court
• Federal District Courts
• U.S. Court of Federal Claims
• Ninth and Tenth Circuit Courts of Appeals and the Federal Circuit
• State courts in Arizona, California, Nevada and Utah.
• Handles cases involving disputed tax liabilities, deficiency notices, refund claims and other contested tax issues.

Tax audit representation

• Representation in IRS and state income, employment and other tax audits.
• Assists with responding to audit notices, organizing documentation, and communicating directly with revenue agents and appeals officers.
• Handles administrative appeals of audit results.

Tax collections

• Defense in IRS and state collection matters, including:
• Liens and levies
• Wage garnishments
• Seizures
• Assists with installment agreements, Offers in Compromise, penalty abatement requests, and other collection alternatives.
• Advises on options such as Currently Not Collectible (CNC) status where appropriate.

Innocent spouse relief

• Represents taxpayers seeking relief from joint tax liabilities arising from a spouse or former spouse.
• Assists with preparing and presenting claims for Innocent Spouse Relief and related remedies.

Foreign tax reporting / offshore voluntary disclosure

• Advises on compliance and controversy matters involving foreign accounts, offshore income and information reporting.
• Represents clients in voluntary disclosure, streamlined filing and related IRS programs.

Marijuana and cannabis industry tax law (Section 280E)

• Represents cannabis and marijuana-related businesses in tax disputes, including application of Internal Revenue Code § 280E.
• Provides audit and litigation defense in cannabis‑related tax matters.

White collar criminal tax defense

• Defense of criminal tax investigations and prosecutions, including alleged tax evasion, filing of false returns and other federal tax crimes.
• Representation at all stages, from investigation through trial and appeal, where applicable.

Tax expert witness and CPA representation

• Serves as tax expert witnesses in federal and state tax disputes.
• Represents CPAs before the Arizona State Board of Accountancy and in matters involving accounting boards.
• Provides litigation support, expert opinions and testimony in complex tax cases.

Types of clients

• Individuals facing IRS or state audits, collections or criminal tax investigations.
• Businesses of all sizes, including closely held companies and cannabis-industry businesses.
• Tax professionals and CPAs involved in regulatory or disciplinary proceedings.

Main office – Scottsdale, Arizona

Silver Law PLC – Main Office 7033 E. Greenway Pkwy, Suite 200 Scottsdale, AZ 85254 Phone: (480) 429-3360 Fax: (480) 429-3362 Email: [email protected]

Additional office locations

Las Vegas / Henderson, Nevada Silver Tax Resolution Services LLC 2470 Saint Rose Parkway, Suite 207 Henderson, NV 89074 Phone: (702) 801-1000

San Diego, California Silver Law LLP 7676 Hazard Center Drive, Suite 1525 San Diego, CA 92108 Phone: (619) 387-3790

Coronado, California Silver Law LLP 724 1st St. Coronado, CA 92118 Phone: (619) 612-5337

Draper / Salt Lake City, Utah Silver Law PLC – Utah 11576 S. State Street, Suite 1002 Draper, UT 84020 Phone: (801) 340-7514

Office hours

• Standard office hours: Monday through Friday, 9:00 am – 5:00 pm (local time).
• Evenings and weekends are available by appointment only.

Service area

• Represents clients in Arizona, California, Nevada, Utah and across the United States in federal tax matters.

Notes about contacting the firm

• Using the website contact form or email does not create an attorney–client relationship.
• Do not send confidential or time‑sensitive information until you have spoken directly with the firm.

Ask anyway — the agent will say plainly that it is not published rather than guess.