Victor Jaramillo Comments on Non-Willful Conduct Under Streamlined OVDP
During a recent D.C. Bar Association luncheon, Victor A. Jaramillo commented on how agents will likely react as a result of the IRS not defining "non-willful conduct" under the streamlined version of the offshore voluntary disclosure program (OVDP). For the complete article, please click on the link above to view a PDF.
Excerpt taken from the article.
During the main discussion, panelist Victor Jaramillo of Caplin & Drysdale said agents are likely to be detailed and thorough as they try to determine whether a taxpayer's conduct was willful. He raised a situation where a person used a professional to file returns. He said it is possible the IRS agent handling the case may ask for the name of the professional and the advice that was given, and may contact that professional as part of the inquiry.