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SANDRA R. BROWN quoted in “CI Expecting More Fraud Referrals From IRS Operating Divisions”, Tax Notes

IRS CI wants more fraud referrals – from the IRS Operating Divisions.

The value of the IRS’s ongoing voluntary disclosure program, both to non-compliant taxpayers and the IRS, for the goals of obtaining and encouraging tax compliance is without question.  On July 19th, Don Fort, Chief of IRS Criminal Investigation, while speaking at the University of San Diego School of Law and RJS Law Tax Controversy Institute in San Diego, noted that while only 7 percent of the cases that CI receives come from the IRS operating divisions, he expects that to change now that the issue has gotten the attention of IRS Commissioner Charles Rettig.   Chief Fort also noted that while the ongoing voluntary disclosure program is operated by the IRS Large Business and International Division, CI has access to everything a taxpayer submits to that program. In fact, CI is still developing leads based on the data provided under the previous iterations of the program that focused on offshore accounts, he said.

Sandra R. Brown of Hochman Salkin Toscher Perez P.C. pointed out that taxpayers in the voluntary disclosure program are spared criminal prosecution only if they are pre-cleared to participate and then fully comply with IRS examiners once they’re cleared, anyone who thinks they can come into the program, provide their information to the IRS, and then opt out if they don’t like the results has no guarantee of immunity to further prosecution, she emphasized.  “There is no absolute guarantee of immunity unless you get it from the DOJ,” said Brown, former Acting U.S. Attorney for the Central District of California and Chief of its Tax Division before that.

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