IRS Domestic Voluntary Disclosure Attorney Atlanta

IRS Domestic Voluntary Disclosure Attorney Atlanta
In contract to the Offshore Voluntary Disclosure Program, where our clients have unreported income and bank accounts overseas, a Domestic Voluntary Disclosure, from herein called DVD, is an IRS program where the U.S. based tax payer has unreported income from U.S. sources only.
For instance, you are a landlord or a business owner where you received payment that was never reported (Note: This is not a payroll tax or sales tax issue where you withheld money that was collected and was to be kept in escrow and then submitted to the government). Over the years, the income has accumulated and now you are thinking “what if I get caught?” At that point, you are most likely thinking about making a DVD.
Voluntary disclosure treatment is not available if the IRS has learned of the taxpayer’s liability through the news media, an informant, bank reporting or the fruits of its own investigation. Also, voluntary disclosure does not protect a taxpayer whose unreported income was from an illegal source.
If you are already the target of an IRS criminal investigation or prosecution, our tax attorneys have substantial experience defending clients facing the IRS criminal investigation process or prosecution for federal tax crimes. When your problem is a pending or potential IRS criminal tax investigation, you need serious help.
Our law firm has been dealing with an increasing amount of DVD’s since the IRS and other governmental agencies have been receiving less money from taxpayers than needed to keep things afloat. Small business audits are increasingly on the rise and auditors are looking carefully into how much people are spending, depositing, and reporting. We have been successful in shifting this problem from a criminal penalty to a civil penalty. The expectation should be to pay out money to the IRS, but not jail time.
Once the disclosure is made, a special agent will evaluate it. If the agent deems it to be truthful and complete, he or she will so indicate to the special agent in charge. According to the IRM, the evaluation should be completed within 10 working days from when it was received. The disclosure doesn’t have to be communicated in any particular format, but processing it will require information outlined in IRM 9.5.11.9.6.
If the IRS accepts the disclosure, it is agreeing to take it into consideration in deciding whether to recommend prosecution by the Justice Department. If all other factors are met, the disclosure may result in prosecution not being recommended.
IRS Domestic Voluntary Disclosure Attorney Atlanta