Tax Blog

For more than three-quarters of a century, the IRS has had some form of a Voluntary Disclosure Program.  These programs have invited non-compliant taxpayers who have willfully cheated the government to make amends and come back into compliance.  In return, the taxpayer benefits from reduced penalties and non-prosecution in return for self-reporting.  On August 25, 2026, the IRS Criminal Investigation Chief announced that the IRS would release within the next 60 days a new version of the Voluntary Disclosure Program.  That announcement has been long awaited and sorely needed.

The ...

Last week, the Fifth Circuit in Matter of Diaz invalided a bankruptcy court rule that would have required that taxpayers make available to creditors any current or projected tax refund in excess of $2,000.  Docket No. 19-50982 (5^th Cir., Aug. 26, 2020).

The perfect storm is developing for this issue to affect a growing number of taxpayers.  Due to the economic downturn during the Coronavirus pandemic, a record number of bankruptcies is anticipated.  Also expected is a potentially unprecedented number of tax refunds as a result of the Coronavirus Aid, Relief, and Economic Security ...