Update on the Offshore Disclosure litigation of Maze et. al. v IRS

Update on the Offshore Disclosure litigation of Maze et. al. v IRS

Maze et al v. IRS (Case 1:15-cv-01806-CKK) what we consider a noble attempt to get the IRS to act not so unreasonably. The IRS of course thinks of itself as reasonable as it gives taxpayers an alternatives to the Standard Offshore Penalty of 27.5% or 50%: Taxpayer can request an opt-out for a potentially reduced penalty. But it is that part that is the issue. The IRS is hell-bent on assessing penalties as harshly as the law allows in order to intimate those who have not "come clean." While our clients are all succeeded with Opt-out audits, the process is not for the faint of heart. The alleged remedy of the IRS is not a real choice for some. A small glimmer of hope many taxpayers saw was that in 2014, the IRS greatly liberalized the rules. And it allowed certain "non-wilful" filed to pay a reduced penalty of 5%. From our experience those who were grantd treatment and those were decided on capriciously. Worse, there is no appeal of a Revenue Agents determination that a taxpayer in not entitled to transitional treatment. The IRS claims the is an appeal, just "simply" opt-out and there are plenty of appeals. But as we explained, this is not a great option. Or if it is a great option too attorneys and taxpayers are intimidated by the process. Hence this litigation. We hope the Plaintiffs and their attorneys the best. But our fear it that will will take extraordinary courage by the DC District Court to rule in their favor. http://ift.tt/2lkq8Ey https://youtu.be/Ol2EDcfEL7M IRS Medic