The Voluntary Disclosure Program for undisclosed foreign account follows a fairly logical path. The IRS is apparently tired of the path and is blazing a new course through uncharted jungle.
Step 1 is to clear Criminal Investigations. You know this has happened when you get a letter. From Criminal Investigations. Logical.
Step 2 is the audit. Under the current procedures you get an Information Document Request from Philadelphia and you respond with answers and documents.
Today we received an Information Document Request for someone who hasn’t completed Step 1. This person did not submit the follow-up “optional format” letter to Criminal Investigations.
What this means is that the IRS completely jumped over Step 1 and straight to Step 2. I kind of makes you wonder why CI’s time and resources were burned up with this process.
The Information Document Request has a deadline of January 15, 2010.
That’s the real WTF. Today is December 22, 2009, friends. You expect meaningful action by January 15, 2010?
Merry Christmas, IRS. All of this confusion is optional. And unnecessary.