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Journal of Tax Practice and Procedure – Where’s Waldo? The IRS’s Search for High-Income Non-Filers by ROBERT HORWITZ and SANDRA BROWN

The tax system of the United States is often described as one of “voluntary compliance.”  However, there is little about the filing of required tax returns and paying amounts legally due that is truly voluntary.  The reality is taxpayers have a “legal duty” to comply with U.S. tax laws.  It is no great secret that hundreds of thousands of Americas do not file their tax returns each year.  In 2020, the IRS renewed its focus on those classified as high-income non-filers, defined by the IRS as taxpayers whose income equals or exceeds $100,000 during a tax year and fail to file an income tax return with the IRS.   In this article, Robert and Sandra discuss the impact high-income non-filers have on the “Tax Gap” and the tools the IRS has to collect financial information about these non-compliant individuals. 

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Robert S. Horwitz is a Principal at Hochman Salkin Toscher Perez P.C., former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division.  He represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending clients in criminal tax investigations and prosecutions. Additional information is available at http://www.taxli

Sandra R. Brown is a Principal at Hochman Salkin Toscher Perez P.C., and former Acting United States Attorney, First Assistant United States Attorney, and the Chief of the Tax Division of the Office of the U.S. Attorney (C.D. Cal). Ms. Brown specializes in representing individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court. 

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