We have some voluntary disclosure of bank account cases at the end of the road — the civil audit. We don’t have any that have actually closed yet.
Now I know why. The IRS doesn’t have the paperwork done yet to actually close an amnesty case.
The paperwork needed is colloquially called a “906” agreement.
IRS Counsel in Washington DC is busy amending the 906 closing agreement for voluntary disclosure cases. They had a form up on the shared drive internally at the IRS until a few weeks ago.
In other words, you can’t get to the finish line because the IRS hasn’t finished painting the finish line on the track. 🙂