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, 2009
Jay N. Johnson
Supervisory Special Agent
Los Angeles Field Office
801 Civic Center Drive West
Room 218, MS 8000
Santa Ana, CA 92701
Delivered via fax to 714-347-9561
Subject: Voluntary Disclosure Regarding Offshore Activities
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. Hodgen
Copy (with enclosures): (Client)
Philip D. W. Hodgen is the principal attorney of HodgenLaw PC, an international tax law firm based in Pasadena, California. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law. Admitted to the California bar in 1982, Phil spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991.
Phil is a past chair of the International Tax Committee of the State Bar of California's Tax Section and was a member of the Executive Committee of the State Bar of California's Tax Section for 2004-2007. Phil frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, and real estate professionals.
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