If you’ve been caught in the “bait and switch” of OVDP, or have received notice of penalties for “quiet filing” that you feel are egregious, there may still be hope. The Taxpayer Advocate Service, the IRS’s “best kept secret,” may be able to help you when all other options have been exhausted.
Jack Townsend recently posted on his blog, Federal Tax Crimes, asking if anyone had received help from the Taxpayer Advocate Service for FATCA related issues. One early commenter said that he had turned to TAS for help when audited following OVDP. While he didn’t receive a waiving of the penalties, he did see the penalties substantially decreased.
However, he warns, be respectful of your IRS audit officer and let them know that you are planning to contact TAS. As always, these people are humans and, by and large, their hands are tied. Being kind and respectful is a good way to ensure that they give you breaks when and where they can.
So if you have received a notice of audit, or if you are currently being charged with penalties, have a read through the comments on this blog post and consider appealing to TAS.
If you have appealed to TAS already, I heartedly encourage you to post in the comments or e-mail me at email@example.com with your story.