I previously expressed concerns about the IRS VDP Practice reflected in Form 14457, Voluntary Disclosure Practice Preclearance and Application (November 2024) I was concerned with the requirement that the taxpayer admit criminal willfulness in order to complete parts of the application. IRS Voluntary Disclosure Practice (VDP) Requires Taxpayer Admit Criminal Willfulness (11/29/24; 1/5/25), here.
The purpose of this post is to alert practitioners of the ABA Tax Section’s Comments on the Form 14457. See 12/20/24 Abreu Cover Letter to Werfel, Commissioner, with Comments on VDP and Streamlined Filing, TN here.
I do not offer further comments principally for lack of time and energy (I came down with a significant serious flue-type affliction shortly after Christmas, and have not regained full energy but should later next week (in which I case I might offer comments by expanding this blog entry)). In addition, I am not yet sure that my comments could add anything material to the ABA Tax Section comments. See the list of persons contributing to the comments.
I also alert readers that I have significantly revised (or re-revised) the VDP discussion in my Federal Tax Procedure Book. The revisions are here. See also Federal Tax Procedure Book 2024 Editions Updates (7/26/24; 1/5/25), here.
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