tag:blogger.com,1999:blog-1519969502186924526.post6405808134478906921..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Ex Post Facto "Correction" by Delinquent or Amended Returns After the CI Agent Shows Up (6/10/13)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-1519969502186924526.post-55062283589619690212013-06-12T12:54:36.949-05:002013-06-12T12:54:36.949-05:00What about cases in which the taxpayer amends retu...What about cases in which the taxpayer amends returns and pays the tax before the IRS becomes aware of the problem? I am thinking of this in the context of OVDI. In truly voluntary disclosures (I am excluding those who were informed that their details were about to be disclosed) the taxpayer pays back taxes, and I seem to recall that somewhere in the IRM it says that no FBAR penalty should be assessed if taxes have been paid. Not that if taxes have been paid at the time they were due, but if taxes have been paid, period.Guestnoreply@blogger.com