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STEVEN TOSCHER Quoted in Tax Notes on IRS Voluntary Disclosure Guide Reveals New Details of Practice

A recently acquired IRS guide for voluntary disclosure practice (VDP) examiners provides insights into the IRS’s actions and priorities within the practice and could give practitioners more confidence and familiarity with it.

Steven Toscher weighs in and states cooperation has always been an essential condition of the practice, though that is not to say that the IRS’s position toward voluntary disclosure remains unchanged.  Toscher further states “It’s always been be prepared for open kimono,” “The government has morphed cooperation into part of their data gathering function. . . . Maybe 70 percent is you fixing your sins. The other 30 percent — they are not interested in you; they’re interested in other data.” Acknowledging that the data analysis is smart practice on the part of the IRS, Toscher wondered whether the reinvigorated practice would be too much for some taxpayers that signed up to get into compliance and not to be a “data guinea pig.”

He cited the lack of disclosure from the IRS on statistics of voluntary disclosures over the last several years as evidence that some taxpayers may be hesitant to enter the practice.

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