by Fresh Start Tax | Jul 17, 2013 | IRS Tax Audit
If you have received an IRS nasty gram you are not alone.
Millions of taxpayers every year receive an IRS tax audit notice letting him know that a tax audit is about to take place. Most people get scared to death of what will happen next but being former IRS agents and managers most people do not need to worry themselves into anxiety and panic attacks. All this will pass.
The best way to defend yourself against an IRS tax audit is by contacting former IRS agents and managers who understand the scope of the length and the complete details of what will take place.
Our firm has a A+ rating by the Better Business Bureau and we have been in private practice since 1982.
We are tax experts in IRS tax audits. We completely understand the what, the who, the why, and the complete scope of your IRS tax audit. Being former IRS agents and managers we have conducted audits and have represented taxpayers that are going through on its. We know every single process there is in the system as well of all the appellate protocols.
Besides having former IRS agents and IRS audit managers we also have on staff former IRS appeals agents and tax attorneys for more difficult and complicated cases.
We are a full service tax firm and all our work is conducted by our in-house tax professionals and IRS specialty tax audit experts.
Odds of a IRS Tax Audit
No adjusted gross income 3.42%
$1- $25,000 1.22
$25,000-$50,000 .73%
$50,000-$75,000 .83%
$75,000-$100,000 .82%
$100,000-$200,000 1%
$200,000-$500,000 2.66%
$500,000-$1,000,000 5.32%
1,000,000-$5,000,000 5.38%
$5,000,000-$10,000,000 20.75%
over $10,000,000
What is an IRS audit?
An IRS audit is a review/examination of an organization’s or individual’s accounts and financial information to ensure information is being reported correctly, according to the tax laws, to verify the amount of tax reported is accurate.
You can find more information on Publication 556, Examination of Returns, Appeal Rights and Claims for Refund explains the audit process in more detail.
The IRS Tax Audit Selection Process
Selecting a income or business tax return for a IRS audit does not always suggest that an error has been made. Tax Returns are selected using a variety of methods, including:
- Random selection and computer screening – sometimes returns are selected based solely on a statistical formula. These are very difficult tax audits
- Document matching – when payor records, such as Forms W-2 or Form 1099, don’t match the information reported. 1.6 million taxpayers go through these audits every year.
- Related examinations – returns may be selected for audit when they involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for audit. These are usually high dollar cases.
IRS Tax Audit Methods
An audit may be conducted by mail or through an in-person interview and review of the taxpayer’s records.
The interview may be at an IRS office (office audit) or at the taxpayer’s home, place of business, or accountant’s office (field audit).
The IRS will tell you what records are needed. Audits can result in no changes or changes. Any proposed changes to your return will be explained.
IRS Tax Audit Notification
Should your account be selected for audit, you will be notified in two ways:
In the case of a telephone contact, the IRS will ALWAYS send a letter confirming the audit. E-mail notification is not used by the IRS. If you ever receive an email notice from the Internal Revenue Service you can be sure of one thing is a scam.
Your Rights During an Audit
Publication 1, Your Rights as a Taxpayer, explains your rights as a taxpayer as well as the examination, appeal, collection, and refund processes.
These audit rights include:
- A right to professional and courteous treatment by IRS employees.
- A right to privacy and confidentiality about tax matters.
- A right to know why the IRS is asking for information, how the IRS will use it and what will happen if the requested information is not provided.
- A right to representation, by oneself or an authorized representative.
- A right to appeal disagreements, both within the IRS and before the courts.
IRS Tax Audit Length
The length of each audit varies depending on the type of audit, the complexity of items being reviewed, the availability of information being requested, the availability of both parties for scheduling of meetings and your agreement or disagreement with the findings. Office audits are relatively simple and you are required to go into the local IRS office while field audits can last anywhere from 30 days to two years.
Tax Records that will be needed
You will be provided with a written request for specific documents needed. If you don’t have all the requested documentation you can provide reconstructive records. To do this you should contact us today and we can walk you through the process of tax reconstruction.
The law requires you to retain records used to prepare your return.
Record keeping requirement
Those records generally should be kept for three years from the date the tax return was filed.
The IRS does accept some electronic records. Most revenue agents or field audits generally accept electronic records.
If records are kept electronically, the IRS may request those in lieu of or in addition to other types of records. Contact your auditor to determine what can be accepted to ensure a software program is compatible with the IRS’s.
Audit Determinations
An audit can be concluded in three ways:
1. No change: an audit in which you have substantiated all of the items being reviewed and results in no changes. This is obviously the greatest news you will ever have for a tax audit.
2. Agreed: an audit where the IRS proposed changes and the taxpayer understands and agrees with the changes. The next step will be how to pay the tax deficiency.
3. Disagreed: an audit where the IRS has proposed changes and the taxpayer understands, but disagrees with the changes.
Agreed tax audit cases
If you agree with the audit findings, you will be asked to sign the examination report or a similar form depending upon the type of audit conducted.
If money is owed, there are several payment options available. Publication 594, The IRS Collection process, explains the collection process in detail.
What happens if you disagree with the IRS tax audit findings?
A conference with a manager may be requested for further review of the issue or issues. In addition, Fast Track Mediation or an Appeal request may be filed.
Fast Track Settlement (Large Business and International Division Taxpayers)
Fast Track Settlement (FTS) offers Large Business and International Division (LB&I) taxpayers a way to resolve audit issues during the examination process in less than 120-days.
Working with LB&I and Appeals, taxpayers can use the settlement authority and mediation skills of Appeals to shorten their overall experience with the Internal Revenue Service.
FTS reduces the combined LB&I-Appeals process time by two years.
Fast Track Settlement (Small Business and Self-Employed Taxpayers)
Small Business/Self-Employed and Appeals have designed an alternative dispute resolution strategy for small business and self-employed taxpayers, called the SB/SE Appeals Fast Track Settlement.
The FTS program was designed to resolve audit issues during the examination process within a goal of 60 days from acceptance of the application in Appeals.
The process uses the settlement authority and mediation skills of Appeals. We’ve successfully tested the program in Chicago; St. Paul, Minn.; Houston; central New Jersey; Philadelphia; San Diego; Laguna Niguel and Riverside, Calif.
SB/SE and Appeals will continue to offer FTS in these locations and has now expanded the program to include Atlanta, Detroit, New York City, Phoenix, Tampa and Seattle. FTS will be offered nationwide later in 2013.
To apply for the SB/SE FTS program, the taxpayer and the group manager need to submit Form 14017, Application for Fast Track Settlement, and the taxpayer’s brief, concise and soundly written response to the Service’s position.
IRS Tax Audits – What, Who, Why, Scope of a IRS Tax Audit, Former IRS Agents
by Fresh Start Tax | Jul 11, 2013 | Offer in Compromise
If you want to seek IRS debt forgiveness for back taxes you will need to consider the IRS tax debt settlement program called the offer in compromise.
The offer in compromise is the only IRS debt forgiveness program that allows you to settle your tax debt for pennies on a dollar.
38% of all offers in compromise are accepted by the Internal Revenue Service but it should be noted that 80% of those accepted are submitted by a professional tax firm that has experienced tax professionals preparing the IRS debt forgiveness forms called the offer in compromise.
My Recommendation as a Former IRS Settlement Agent
I would highly instruct all taxpayers wishing for this IRS debt forgiveness to seek professional tax help not because I am in the business but because I am the former IRS settlement officer and know the entire offer in compromise program since I was a teaching instructor with the Internal Revenue Service.
What taxpayers do not understand these forms must be very specific, very detailed and that IRS is looking for a way not to work these cases because of all the work that is required.
It is much easier for the IRS agent to decline the IRS debt forgiveness package than to accept it.
To work in offer in compromise accepted package takes anywhere from 20 to 25 hours. Not only that, it also should be noted that three managers or supervisory signatures are required as well as IRS District Counsel and these packages go up and down the line. It will be well worth the money spent for a taxpayer to find a firm whether it’s us or somebody else that has experienced tax professionals to submit the offer, if and only if, they are a qualified candidate for the IRS debt forgiveness program called the offer in compromise
You can find the IRS debt forgiveness pre-qualifier tool on our website.
I recommend any taxpayer wishing to submit an offer in compromise to walk through this pre-qualifier tool.
What is a Offer in Compromise
An offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can’t pay your full tax liability, or doing so creates a financial hardship.
IRS considers your unique set of facts and circumstances such as :
IRS will generally approve an offer in compromise when the amount offered represents the most we can expect to collect within a reasonable period of time.
Make sure you are eligible before filing for IRS Debt Forgiveness
Before the IRS can consider your offer, you must be current with all filing and payment requirements.
You are not eligible if you are in an open bankruptcy proceeding.
Submit your offer in compromise
You’ll find step-by-step instructions and all the forms for submitting an offer in the Offer in Compromise Booklet, Form 656-B (PDF).
Your completed offer package will include:
- Form 433-A (OIC) (individuals) or 433-B (OIC) (businesses) and all required documentation as specified on the forms;
- Form 656(s) – individual and business tax debt (Corporation/ LLC/ Partnership) must be submitted on separate Form 656;
- $150 application fee (non-refundable); and
- Initial payment (non-refundable) for each Form 656.
Selecting a payment option for the Offer in Compromise
Your initial payment will vary based on your offer and the payment option you choose:
Lump Sum Cash.
Submit an initial payment of 20 percent of the total offer amount with your application. Wait for written acceptance, then pay the remaining balance of the offer in five or fewer payments.
Periodic Payment:.
Submit your initial payment with your application.
Continue to pay the remaining balance in monthly installments while the IRS considers your offer. If accepted, continue to pay monthly until it is paid in full.
If you meet the Low Income Certification guidelines, you do not have to send the application fee or the initial payment and you will not need to make monthly installments during the evaluation of your offer. See your application package for details.
Understanding the Offer process
While your offer is being evaluated:
- Your non-refundable payments and fees will be applied to the tax liability (you may designate payments to a specific tax year and tax debt);
- A Notice of Federal Tax Lien may be filed;
- Other collection activities are suspended;
- The legal assessment and collection period is extended;
- Make all required payments associated with your offer;
- You are not required to make payments on an existing installment agreement; and
- Your offer is automatically accepted if the IRS does not make a determination within two years of the IRS receipt date.
Contact us today for a free tax evaluation on the IRS debt forgiveness program on back taxes called the offer in compromise.
You will speak to a true tax professional who is both affordable and experienced and will give you an honest opinion on where you stand with the IRS.
IRS Debt Forgiveness on Back Taxes, Former IRS, Affordable Debt Experts
by Fresh Start Tax | Jul 2, 2013 | Tax Levy and Wage Garnishments
There is a very specific process to stop an IRS wage garnishment.
As a former IRS agent I have issued thousands of bank levies and IRS wage garnishment’s and I can tell you firsthand there is only one way to go ahead and release any IRS wage levy garnishment.
First Things First, What is a IRS WAGE GARNISHMENT?
A IRS WAGE GARNISHMENT is a legal seizure of your property to satisfy a back tax debt.
Levies or garnishments are different from liens. A lien is a claim used as security for the tax debt, while a levy actually takes the property to satisfy the tax debt.
If you do not pay your taxes or make arrangements to settle your debt the IRS may seize and sell any type of real or personal property that you own or have an interest in.
What IRS has the right to do.
IRS can seize and sell property that you hold such as your car, boat, or house or IRS
could levy property that is yours but is held by someone else such as your wages, retirement accounts, dividends, bank accounts, licenses, rental income, accounts receivables, the cash loan value of your life insurance, or commissions.
These three requirements are must be met for IRS to levy wages:
- They assessed the tax and sent you a Notice and Demand for Payment;
- You neglected or refused to pay the tax; and
- They sent you a Final Notice of Intent to Levy and Notice of Your Right to A Hearing (levy notice) at least 30 days before the levy.
IRS may give you this notice in person, leave it at your home or your usual place of business, or send it to your last known address by certified or registered mail, return receipt requested.
If you have a hardship situation, contact us immediately.
A levy/garnishment release does not mean you are exempt from paying the balance.
The IRS will work with you to establish payment plans or take other steps to help you pay off the balance.See below.
Important Note to Employers who receive IRS Wage Garnishment on Employees
Employers generally have at least one full pay period after receiving a Form 668-W, Notice of Levy on Wages, Salary and Other Income before they are required to send any funds from their employee’s wages.
You can always ask the IRS manager to review the case.
You may ask an IRS manager to review your case, or you may request a Collection Due Process hearing with the Office of Appeals by filing a request for a Collection Due Process hearing with the IRS office listed on your notice.
Option of File an Appeal
You must file your request within 30 days of the date on your notice. Some of the issues you may discuss include:
1. You paid all you owed before we sent the levy notice,
2. IRS assessed the tax and sent the levy notice when you were in bankruptcy, and subject to the automatic stay during bankruptcy,
3. IRS made a procedural error in an assessment,
The time to collect the tax (called the statute of limitations) expired before we sent the levy notice,
4. You did not have an opportunity to dispute the assessed liability,
5. You wish to discuss the collection options, or
6. You wish to make a spousal defense.
At the conclusion of your hearing, the Office of Appeals will issue a determination. You will have 30 days after the determination date to bring a suit to contest the determination. Refer to Publication 1660 (PDF), for more information.
If your property is levied, garnished or seized, contact the employee who took the action. You also may ask the manager to review your case. If the matter is still unresolved, the manager can explain your rights to appeal to the Office of Appeals.
How to Stop the IRS Wage Garnishment
To stop the IRS wage garnishment you will need to give the Internal Revenue Service a current financial statement and that will be need to given on form 433f, you can find that form on our website.
Make sure you fill out an honest and accurate financial statement because IRS will verify everything that is on that financial statement along with all documentation.
IRS will also request the last 3 to 6 months worth of bank statements and your last pay stub.
IRS will then conduct a national and regional standards test and compare them against your financial statement. The purpose for this, IRS wants to make sure you’re living within your means.
Once IRS compares your financial statement against the standards, IRS will suggest to you that your case is either eligible for a economic tax hardship which is called currently noncollectable or IRS will demand an installment payment agreement, or IRS will recommend to you that you are an offer in compromise candidate.
Once IRS has your current financial statement and makes a determination on your case they will release your wage levy garnishment as a general rule that same day.
The Key to getting a Wage Garnishment Release
The key to get immediate release of an IRS wage garnishment is to call the Internal Revenue Service and be ready to fax the financial statement with all verifying information to the agent on the phone and have IRS make a determination right then and there.
Contact us today for a free initial tax consultation and see how we can stop your IRS wage garnishment and settle your tax case.
Do not be bullied by the Internal Revenue Service.
How to STOP a IRS Wage Garnishment, Former IRS Agent Explains
by Fresh Start Tax | Jun 25, 2013 | FBAR
It’s here again and it’s never going away. The annual FBAR filing date.
This year June 30, 2013.
The federal government loves to receive this birthday gift of the filings of FBAR.
In the last three filing seasons the federal government collected over $5.5 billion on Fbar alone and the federal government feels there are over $300 billion more to collect and they are on a diligent hunt to collect all the money that’s out there that they feel belongs to them.
It is in anyone’s best interest who is required to file to make sure they file this report timely because the IRS and the federal government are not going the way away and the fear of criminal prosecution is looming large over those who have yet to make a decision.
Being a former IRS agent and not trying to put fear in anybody, I would suggest anyone who has yet to file, to contact our office today for free tax consultation about their particular facts and situation and find out the different solutions available to them and about the abatement of penalties and interest.
If you are required to file you MUST file by June 30, 2013.
Who has File?
U.S. persons having a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account may be required by the Bank Secrecy Act to report their interest in the account to the IRS by filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
A U.S. person may have a reporting obligation even though the foreign financial account does not generate any income.
If a U.S. person had such a financial interest or signature authority at any time during calendar year 2012, the FBAR must be received by the Department of the Treasury on or before June 30, 2013.
The FBAR is not filed with the federal income tax return. The granting by the IRS of an extension to file federal income tax returns does not extend the due date for filing an FBAR. The June 30th filing date may not be extended.
FBAR filers report their foreign accounts by (1) completing boxes 7a and 7b on Form 1040 Schedule B; box 3 on the Form 1041 “Other Information” section; box 10 on Form 1065 Schedule B; or boxes 6a and 6b on Form 1120 Schedule N and filing the FBAR, satisfies the account holder’s reporting obligation.
Even if all relevant information is not available, the FBAR should be filed with as much information as is available; the FBAR can be later amended (by checking the “Amended” box in the upper right corner of the first page of the FBAR) when the additional or new information becomes available.
Having Financial Interest
A United States person having a financial interest in or signature authority over a foreign financial account must file an FBAR if the aggregate value of all foreign financial accounts exceeds $10,000 at any time during the calendar year.
A United States person includes U.S. citizens; U.S. residents; entities, including but not limited to, corporations, partnerships, or limited liability companies created or organized in the U.S. or under the laws of the U. S.; and trusts or estates formed under the laws of the United States.
The term PERSON
The term “person” means an individual and legal entities including, but not limited to, a limited liability company, corporation, partnership, trust, and estate. A U.S. resident includes an alien residing in the United States.
To determine whether the U.S. person is a resident of the U.S., look for guidance in the residency tests set forth in 26 U.S.C. §7701(b).
A single-member LLC, which is a disregarded entity for U.S. tax purposes, is a U.S. person for FBAR filing purposes since the tax rules concerning disregarded entities do not apply with respect to the FBAR reporting requirement (FBARs are required under Title 31, not under any provisions of the Internal Revenue Code).
Financial Account.
A financial account includes, but is not limited to, a securities, brokerage, savings, demand, checking, deposit, time deposit, or other account maintained with a financial institution (or other person performing the services of a financial institution).
A financial account also includes a commodity futures or options account, an insurance policy with a cash value such as a whole life insurance policy, an annuity policy with a cash value, and shares in a mutual fund or similar pooled fund i.e., a fund that is available to the general public with a regular net asset value determination and regular redemption’s.
Foreign Financial Account.
A foreign financial account is a financial account located outside of the United States. For example, an account maintained with a branch of a United States bank that is physically located outside of the United States is a foreign financial account.
An account maintained with a branch of a foreign bank that is physically located in the United States is not a foreign financial account.
Foreign Country
A “foreign country” includes all geographical areas outside the United States, the commonwealth of Puerto Rico, the commonwealth of the Northern Mariana Islands, and the territories and possessions of the United States (including Guam, American Samoa, and the United States Virgin Islands).
Financial Interest. A U.S. person has a financial interest in a foreign financial account for which:
(1) the U.S. person is the owner of record or holder of legal title, regardless of whether the account is maintained for the benefit of the U.S. person or for the benefit of another person; or
(2) the owner of record or holder of legal title is one of the following:
(a) An agent, nominee, attorney, or a person acting in some other capacity on behalf of the U.S. person with respect to the account;
(b) A corporation in which the U.S. person owns directly or indirectly: (i) more than 50 percent of the total value of shares of stock or (ii) more than 50 percent of the voting power of all shares of stock;
(c) A partnership in which the U.S. person owns directly or indirectly: (i) an interest in more than 50 percent of the partnership’s profits (e.g., distributive share of partnership income taking into account any special allocation agreement) or (ii) an interest in more than 50 percent of the partnership capital;
(d) A trust of which the U.S. person: (i) is the trust grantor and (ii) has an ownership interest in the trust for U.S. federal tax purposes [See 26 U.S.C. § 671-679 to determine if a grantor has an ownership interest in a trust];
(e) A trust in which the U.S. person has a greater than 50 percent present beneficial interest in the assets or income of the trust for the calendar year, unless the trust, a trustee of the trust, or agent of the trust:
(f) is a U. S. person and (ii) files an FBAR disclosing the trust’s foreign financial accounts.; or
(g) Any other entity in which the U.S. person owns directly or indirectly more than 50 percent of the voting power, total value of equity interest or assets, or interest in profits.
Signature Authority.
Signature authority is the authority of an individual (alone or in conjunction with another individual) to control the disposition of assets held in a foreign financial account by direct communication (whether in writing or otherwise) to the bank or other financial institution that maintains the financial account.
Other authority exists in a person who can exercise power that is comparable to signature authority over an account by direct communication to the bank or other person with whom the account is maintained, either orally or by some other means.
There are specified exceptions to the “signature authority only” filing requirement for officers or employees of certain types of banks and entities.
Where to File.
The FBAR is filed by mailing to: Department of the Treasury, Post Office Box 32621, Detroit, MI 48232-0621.
If an express delivery service is used, file by sending the FBAR to:
IRS Enterprise Computing Center ATTN: CTR Operations Mail room, 4th Floor, 985 Michigan Avenue, Detroit, MI 48226.
Delivery messenger service contact telephone number: (313) 234-1062.
The FBAR instructions indicate that it may be hand delivered to any local office of the IRS for forwarding to the Department of the Treasury, Detroit, MI.
The FBAR may also be delivered to the IRS’s tax attaches located in United States embassies and consulates for forwarding to the Department of the Treasury, Detroit, MI.
The FBAR is not considered filed until it is received by the Department of the Treasury in Detroit, MI.
It is interesting to note that a recent study done by the GAO office of the federal government has found for every one dollar the federal government spends on an employee working Fbar it collects six, so it is no wonder you’re going to find much manpower camping in these programs.
Contact us today for free initial tax consultation and speak to a true tax professional
by Fresh Start Tax | Jun 25, 2013 | FBAR
We are asked on a routine basis is there after FBAR amnesty?
The answer flat out is NO!
There is no such program being offered by the federal government that would give a taxpayer a free ride.
The best deal you are you will get with the Internal Revenue Service is by hiring a highly trained and experienced tax professional who knows the ropes through the system and there are many of these tax professionals that exist. IRS is very tough on FBAR.
In the last three filing years they have collected over $5.5 billion on Fbar alone. It is a hot ticket item with the IRS and it not going to stop.
I have read that there is an estimate of over $300 billion still to collect.
Make sure you do your due diligence before engaging in a tax firm.
With that said, there is much at you can do about the abatement of penalties and interest as a result of the government computations of the various penalties that arise from the filing and reporting of Fbar.
You should contact us today for a free initial tax consultation and find out the truth about your particular situation. Let our years with the federal government and extensive work experience be your best friend.
We have been in private practice since 1982 and have over 206 years of professional tax experience.
We are A+ rated by the Better Business Bureau.
We are comprised of tax attorneys, tax lawyers, former IRS agents, managers and tax instructors.
We have over 60 years of working directly for the Internal Revenue Service in a local, district, and regional tax offices of the Internal Revenue Service.
As a result of our years of experience, we know all the protocols, all the formulas, and all the penalty abatement reasonable classes that can serve you well for the situation that you may be now facing
Reasonable Cause Guidelines
Reasonable Cause.
Once IRS tax examiners determine that the taxpayer is in full compliance for all open years (not on extension) with respective provisions of the law, they must consider any reason a taxpayer provides in conjunction with the guidelines, principles and evaluating factors relating to reasonable cause based on the facts and circumstances.
IRS Tax Examiners are mindful of the fact that generally these penalties apply to individuals who have business or investment activities in foreign countries, and, as such, general care and prudence requires researching the filing and tax obligations of all jurisdictions.
Reasonable cause does not apply to the initial penalty in some IRC sections.
Many of the penalty sections have specific provisions for reasonable cause.
IRS Tax Examiners must issue a determination letter if the taxpayer requested reasonable cause consideration and it was denied.
Reasonable cause determinations can only be made by the unit that asserted the penalty e.g., campus cannot allow reasonable cause for a penalty asserted by LB&I, TE/GE, or SB/SE Field Office Examination.
A taxpayer’s repeated failure to file does not support testimony that the taxpayer demonstrated normal business care or prudence for the older, late-filed years.
Once all open periods (not on extension) are secured, examiners can make a determination as to reasonable cause for any of the periods not timely filed.
IRM 20.1.1.3.2.1 lists the standards and authorities for establishing reasonable cause and IRM 20.1.1.3.2.2 defines ordinary business care and prudence.
A taxpayer’s testimony that records were not available year after year has no merit. Once all late filings are secured, examiners can make a determination as to any reasonable cause for all periods secured.
IRM 20.1.1.3.2.2.3 provides criteria for taxpayers unable to obtain records.
It is critical to understand that there are no two cases alike.
Facts and circumstances different from taxpayer to taxpayer and many times a taxpayers history will determine the IRS tolerance in certain situations.
Remember there is no such thing as Fbar amnesty at this current time.
Avoidance Criminal Prosecution
To avoid criminal prosecution your case must be reviewed by an experienced tax attorney or tax lawyer who has extensive experience in working with the Internal Revenue Service. In all honesty there are no two cases the same.
Every case must be thoroughly reviewed before guidance can be given.
As a general rule, the IRS is going to go after high dollar cases and those who have repeatedly violated the law and have made every effort possible to hide or fail to disclose the funds.
When you call our office and you have such a case, you will speak to a tax attorney or tax lawyer in which all conversations will be held under attorney-client privilege.
FBAR Amnesty – Avoidance Criminal Prosecution – Affordable Attorneys, Lawyers, Former IRS
