Martin Silver, PS

Attorney at Law

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Big 2015 Penalty Increases for Late Filing of Washington State Business Taxes

August 8, 2015 by Martin Silver

The Washington State Legislature has just enacted substantial increases to payments for businesses that pay taxes late.  Beginning August 1, 2015, if a return is not paid by the due date the 5% penalty is increased to a whopping 9%!  If the tax is not paid by the end of the second month the penalty… CONTINUE

Filed Under: Tax News

Settlement Options with IRS and Washington State When Your Business Closes

June 5, 2015 by Martin Silver

When a business fails and closes it often has unpaid federal and Washington State taxes. Usually there isn’t much in the way of federal income taxes (Washington State has no income tax) but even if there are unpaid income taxes those will not normally be a serious issue if the business has operated as an… CONTINUE

Filed Under: Federal Audits, Federal Tax Appeals, Internal Revenue Service, State Audits, State Tax Appeals, Washington Department of Revenue

Footnote in IRS Manual Shows How to Save Money on Tax Penalty.

May 30, 2015 by Martin Silver

I recently had a conversation with a colleague concerning an IRS trust fund penalty case he had and was pleased that he had success with a little known footnote in the Internal Revenue Manual (IRM) which may save money for a company officer who would otherwise be liable for a payroll trust fund recovery penalty… CONTINUE

Filed Under: Business & Corporate Taxation, Tax Appeals

Pre-Audit Consultation – Well Worth the Money

March 23, 2015 by Martin Silver

In an earlier article we discussed how our office persuaded the Washington Department of Revenue Appeals Division that our client had correctly reported its B & O tax as a wholesaler, and had no obligation to collect sales tax, even though it had not been able to obtain reseller permits from the out of state… CONTINUE

Filed Under: State Audits, State Tax Appeals

INTEREST RATES for STATE EXCISE TAXES for CALENDAR YEAR 2015

November 29, 2014 by Martin Silver

Clients who are appealing a state tax audit to the Department of Revenue’s appeals division sometimes ask me whether they should pay the items in the audit report that they do not dispute.  They reason that this will save interest and it may improve their position before the appeals division.  Unless I am asked to… CONTINUE

Filed Under: State Audits, State Tax Appeals, State Tax News

Taking a Washington State Reseller Permit not the Only Way to Qualify for Wholesale Reporting

October 6, 2014 by Martin Silver

It is the position of the Department of Revenue that a taxpayer must have taken a Washington State reseller permit (or, before January 1, 2010, a resale certificate) from its customer to qualify its reporting for B & O as wholesale.  Rule 102 provides that: The seller has the burden of proving that the buyer… CONTINUE

Filed Under: State Audits, State Tax Appeals

What is Washington State’s Enhanced Voluntary Disclosure Program?

August 12, 2014 by Martin Silver

There has been talk recently about the Department of Revenue (DOR) “Enhancements” to its Voluntary Disclosure Program (hereafter referred to as “Program”).  That talk suggests that something new is available to businesses wishing to avail themselves of the benefits of voluntary disclosure.    In appropriate circumstances voluntary disclosure may well be beneficial, but the fact… CONTINUE

Filed Under: State Tax News

IRS 1099-K Increases Risk of Washington State Sales Tax Audit

August 3, 2014 by Martin Silver

In 2008 Congress enacted legislation requiring institutions  processing credit cards for businesses that take cards in exchange for goods or services to give such businesses a IRS 1099-K form annually, and to furnish the IRS with a copy of the form.   Section 6050W (which was added to the Internal Revenue Code by the Housing… CONTINUE

Filed Under: State Audits, State Tax News, Tax News

Budget Cuts Strap IRS – But No Free Ride for Certain Filing Missteps

July 26, 2014 by Martin Silver

It is common knowledge among tax practitioners and the informed public that the IRS is strapped for funds, and that this has made it very difficult to reach IRS personnel, reduced audits and slowed collection activities.  But we have heard clients and others say that because of this they are taking little care in what… CONTINUE

Filed Under: Tax News

Sometimes an IRS Mistake is a Good Thing

July 7, 2014 by Martin Silver

It is easy to get discouraged by income tax bills, but it is a bad idea to get discouraged about a tax bill while there are still opportunities to contest the bill.   If a client is willing and has a reasonable basis for challenging the validity of the bill we usually encourage him or… CONTINUE

Filed Under: Federal Tax News, Internal Revenue Service

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About Martin Silver, P.S.

Licensed to practice before the U.S. Tax Court and Washington State and Federal Courts.

Widely recognized authority and lecturer in State, Local and IRS tax matters.

Author of Washington Taxes: Representing Taxpayers Before the Washington Department of Revenue (Butterworth Publishing, 1992), and numerous articles.

"AV" rated by Martindale-Hubbell, the nation's most recognized legal directory.

Contact Us

Martin Silver, P.S.
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101-2393

(206) 224-3461 phone
(206) 224-3459 fax
msilver@wolfenet.com

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1420 Fifth Avenue, Suite 3000, Seattle, WA 98101-2393 | Phone: (206) 224-3461 | Fax: (206) 224-3459 | Email
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