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Author: Lawrence Brown

New IRS Initiative Focuses on High-Income Non-Filers

The Internal Revenue Service (IRS) has announced a new enforcement initiative focused on high-income non-filers. According to a recent News Release, the IRS is specifically targeting high-income taxpayers who failed to file returns between 2017 and 2021. As the IRS calculates failure-to-file and failure-to-pay penalties based on the amount due, […]


An Overview of IRS CI’s Voluntary Disclosure Practice

For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]

Tax Controversy 

What is an “Attempt to Evade or Defeat Tax?”

Tax evasion is a serious federal crime. Individual taxpayers convicted of tax evasion can face up to a $100,000 fine and five years of federal imprisonment, while corporate entities can be fined up to $500,000. This raises an important question: What does it mean to “attempt to evade or defeat […]

Tax Evasion