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Launch your amnesty - sample letter

Portrait of Phil Hodgen

Phil Hodgen

Attorney, Principal

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Here's a lightly adapted version of the letter we use. If you want to launch your own voluntary disclosure for your offshore account, here's what to do:
  • Go to the IRS website and find the address and phone number for the IRS Criminal Investigations office for where you live.
  • Call them and get their fax number.
  • Do the edits you need to do. Don't worry about being Marcel F-ing Proust. Just hack it up and get the info in there.
  • Fax that sumbitch to the IRS.
  • Call them and ask them to confirm that they got your fax.
  • Find someone to buy you a drink.
  • Call me on my mobile at +1-626-437-2500 and hire us to take you from there. Or call someone else. 'Cause you're going to need it.
OK. Jay Johnson is going to hate me. But if you can't figure out where to send your letter, fax it to him. :-) Full info is below helpfully pre-built into this letter. I'm just sayin' that you take the position that you got your letter into the IRS before the deadline. Yeah footfault on the PLACE for filing. But you're in.Remember, I'm not telling you to do this. I'm just giving you the ammo if you need to get it done.Here you go. . . .
October 15, 2009Jay N. Johnson Supervisory Special AgentIRS-Criminal Investigation Los Angeles Field Office 801 Civic Center Drive West Room 218, MS 8000 Santa Ana, CA 92701Delivered via fax to 714-347-9561Subject: Voluntary Disclosure Regarding Offshore Activities Taxpayer: (Name) Social Security Number:Date of Birth:Address on Return:Dear Mr. Johnson:This letter constitutes the above-identified taxpayers’ formal notice to the Internal Revenue Service of their desire to participate in the current program for voluntary disclosure of offshore activities by U.S. taxpayers. The taxpayers are fully willing to cooperate with the IRS in determining the correct tax liability.The voluntary disclosure made relates to Swiss accounts owned by them.Please contact me for follow-up questions. My daytime telephone number is _____________ and my email address is ______________. I will be following up shortly with a second letter, following the guidelines of the “Offshore Voluntary Disclosures – Optional Format” letter published by the IRS on 7/28/2009.I look forward to working with you or one of the Special Agents in your office in order to process this application and receive a determination letter from your office advising that the taxpayers are eligible for the voluntary disclosure program.Very truly yours,Philip D.W. HodgenCopy (with enclosures): (Client)