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High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, June 2, 2021

Recorded event now available

or call 1-800-926-7926

This course will discuss the IRS' recent campaign to bring high-income non-filers into compliance. Our panel of income tax experts will cover bringing these taxpayers into compliance, minimizing penalties and consequences of noncompliance, and handling the complexities of these IRS examinations.


The IRS issued IR 2020-34 on Feb. 18, 2020, announcing its intent to visit non-filers to bring these taxpayers into compliance. The agency uses data-analytics, whistleblower reports, and even tips from neighbors to track down high-income non-filers.

For these taxpayers, those making more than $100,000 and not filing, failure to respond to initial requests can have major repercussions. These can include referral for criminal investigation, prison time, and of course, substantial penalties. The IRS offers a Voluntary Disclosure Program for domestic taxpayers. Taxpayers willing to admit that they "willfully failed to comply" with tax filing obligations may be able to resolve their noncompliance and minimize repercussions. Advisers working with high-income non-filers need to understand when to consider this alternative.

The examination process is detailed and lengthy. Communicating with the IRS, the information document request, mediation, appeals, and, when warranted, litigation are a few of the examination process stages. Tax advisers handling IRS audits must understand the process and how to best represent the taxpayer.

Listen as our panel of IRS examination experts explains how the IRS identifies high-income non-filers, the IRS Voluntary Disclosure Program and when it can be a sensible solution, and tips for handling the IRS audit from start to finish.



  1. The IRS campaign
  2. IRS structure
  3. Non-filer identification process
  4. Repercussions
  5. Voluntary disclosure
  6. IRS examination process
  7. Appeals, mediation, and litigation
  8. Best practices


The panel will review these and other key issues:

  • How the IRS ferrets out high-income non-filers
  • Which taxpayers should consider IRS' Voluntary Disclosure program?
  • What penalties could be assessed to high-income non-filers and how can they be mitigated?
  • Learn when an examination may be referred to the IRS Criminal Investigation Division


Brown, Sandra
Sandra R. Brown

Hochman Salkin Toscher Perez

Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations,...  |  Read More

Perez, Dennis
Dennis L. Perez

Hochman Salkin Toscher Perez

Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax...  |  Read More

Stigile, Cory
Cory Stigile

Hochman Salkin Toscher Perez

Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation...  |  Read More

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CPE credit is not available on downloads.