For taxpayers with potentially willful tax noncompliance, the IRS Voluntary Disclosure Practice (“VDP”) has always offered a metaphorical “carrot and stick” bargain: come forward before the government finds you, disclose the conduct, pay the tax and some penalties, and in return, substantially reduce the risk of criminal prosecution. In recent years, however, that bargain has […] Read More…

In a rare and welcomed victory for taxpayer rights and administrative fairness, the IRS has agreed to remove the willfulness checkbox from the next version of the Form 14457—the application form for the Voluntary Disclosure Practice (VDP). In addition, the program will make allowances not to preclude income derived from marijuana sales by changing its […] Read More…

Dear Colleague- The highly anticipated 2026 UCLA Extension Tax Controversy Conference is fast approaching, and this is an event you don’t want to miss! By registering now through the link below, you can gain invaluable insights through our distinguished keynote speakers, Emin Toro, a respected Judge of the United States Tax Court, and Jarod Koopman, […] Read More…