This brief blog today is to alert readers to an outstanding article on the current state and some uncertainties and risks of the IRS Voluntary Disclosure Practice (“VDP”). Scott Michel and Mark Matthews, The 2020 Revision to the Internal Revenue Manual’s Voluntary Disclosure Practice: More Consistency with Greater Risk (Bloomberg Daily Tax Report 1/12/21), here. The article is prompted by recent changes to the IRM provisions on the VDP. IRM 220.127.116.11(1) (09-17-2020), Voluntary Disclosure Practice, here.
This blog post is cross-posted on my Federal Tax Procedure Blog, here.