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IRS Agrees Not to Prosecute Physician Who Failed to File Tax Returns or Fully Pay Tax Liabilities for Over a Decade


Our client was a well-known physician under IRS criminal investigation for failure to file tax returns and pay tax liabilities for over a decade.


Immediately after being retained we established communication with IRS decision-makers and urged them that separate from his tax non-compliance, our client was a fine physician and a model citizen, that a criminal conviction would likely cost him his medical license, and that our client’s community and the U.S., in general, needed more, not fewer physicians. We advised that our client would file all of the delinquent returns and was in a position to pay the delinquent tax, penalties, and interest. Having no legal defense, we stressed common sense in our negotiations.


The IRS agreed to decline prosecution, and we coordinated the preparation and filing of all delinquent returns, represented our client in an IRS civil audit of those returns and negotiated a payment arrangement that called for a lump sum down payment, followed by installment payments to satisfy the delinquent tax, penalties, and interest.