The IRS has increased its 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. 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
• What is known about the current IRS selection process?
• Which taxpayers and transactions are being targeted?
• How can taxpayers best prepare for potential audits?
• What caveats should tax professionals be wary of when representing taxpayers during high net worth audits?
• When should a taxpayer go to appeals, and how does the current IRS appeals process work?
• The current IRS initiative
• The structure of the IRS
• The selection process
• Proactive preparation
• The examination process
Accountant/CPA Lawyers Financial Advisors.
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