STEVEN TOSCHER DENNIS PEREZ and MICHEL STEIN to Speak on High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Sunday, October 18, 2020
We are pleased to announce that Steven Toscher, Dennis Perez and Michel Stein will be speaking at an upcoming Strafford webinar, “High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance” on Thursday, October 22, 2020, 1:00 p.m. – 2:30 p.m. EDT/ 10:00 a.m. – 11:30 a.m. PST
The IRS has increased their focus and efforts on high income taxpayers who haven’t filed their tax returns. The potential for significant penalties, limited voluntary disclosure options, and possible criminal prosecution forces tax counsel and advisers to grasp a complete understanding of applicable tax rules and procedures when representing high income taxpayers.
On Feb. 19, 2020, the IRS issued IR-2020-34, which states the IRS “will step up efforts to visit high income taxpayers who in prior years have failed to timely file one or more of their tax returns.” The IRS now uses sophisticated data analytics to identify high income non-filers and tax preparers who promote false tax returns, as well as businesses with large amounts of unpaid employment taxes.
Failure to file tax returns can have severe consequences. IRC 6651(a)(1) imposes substantial additions to tax for a failure to file a tax return. Moreover, fraud referrals from the IRS Collection Division have been increasing. There are potential criminal consequences as well: IRC 7203 makes it a misdemeanor to failure to file; if convicted, a taxpayer can be fined up to $25,000 ($100,000 for corporations) in fines and up to one year in prison. Under IRC 7201, a willful failure to file, combined with affirmative acts of evasion, could lead to a potential felony conviction for tax evasion, which can result in up to five years in prison.
We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com.
For full programming details Click Here.
