We originally posted on Thursday, September 18, 2014, "So What Does "Non-Willful" Really Mean Under The Streamlined OVDP?" where we discussed that it appears that whatever Non-Willful means outside of the OVDP streamline program; it is certainly being applied differently in evaluating a Taxpayer’s ability to transition from the OVDP program into this new 2014 streamline program.
We also discussed 2 news reports, both verifying that taxpayers who are currently in the OVDP program are having very little success in proving "non-willfulness" during their requests for transition into the new 2014 streamline procedure.
Upon further reflection, until the IRS gives us their specific interpretation of "Non-Willfulness" under the 2014 Streamline Program; you might want to consult the IRS's Internal Revenue Manual (IRM) for guidance!
This is most likely what the IRS will be consulting in making their determination of whether your clients are "Non-Willful" and qualify
for the 2014 Streamlined OVDP Program!
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if you qualify for the
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