High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Thursday, October 22, 2020

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE/CPE course will provide counsel and tax advisers with guidance on available options for handling high income non-filers and navigating IRS collection issues. The panel will discuss recent IRS enforcement actions for high income taxpayers, voluntary disclosure options, current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.


The IRS has increased their focus and efforts on high income taxpayers who haven't filed their tax returns. The potential for significant penalties, limited voluntary disclosure options, and possible criminal prosecution forces tax counsel and advisers to grasp a complete understanding of applicable tax rules and procedures when representing high income taxpayers.

On Feb. 19, 2020, the IRS issued IR-2020-34, which states the IRS "will step up efforts to visit high income taxpayers who in prior years have failed to timely file one or more of their tax returns." The IRS now uses sophisticated data analytics to identify high income non-filers and tax preparers who promote false tax returns, as well as businesses with large amounts of unpaid employment taxes.

Failure to file tax returns can have severe consequences. IRC 6651(a)(1) imposes substantial additions to tax for a failure to file a tax return. Moreover, fraud referrals from the IRS Collection Division have been increasing. There are potential criminal consequences as well: IRC 7203 makes it a misdemeanor to failure to file; if convicted, a taxpayer can be fined up to $25,000 ($100,000 for corporations) in fines and up to one year in prison. Under IRC 7201, a willful failure to file, combined with affirmative acts of evasion, could lead to a potential felony conviction for tax evasion, which can result in up to five years in prison.

Listen as our panel discusses recent IRS enforcement actions for high income taxpayers, IRS voluntary disclosure options, and tactics to avoid penalties and potential criminal prosecution.



  1. Recent IR-2020-34 and challenges for high income non-filers
  2. IRS enforced collection process
  3. Voluntary disclosure
  4. Collection alternatives
  5. Criminal prosecution


The panel will review these and other key issues:

  • What are the key challenges in representing high income non-filers?
  • What are the IRS penalty structures and pitfalls to avoid as applied to high income non-filers?
  • What is the correspondence chain leading up to enforced collection action by the IRS?
  • What are the remedies and relief provisions to challenge or mitigate a tax lien?


Perez, Dennis
Dennis L. Perez

Hochman Salkin Toscher Perez

Mr. Perez represents and advises U.S. taxpayers in foreign and domestic voluntary disclosures, sensitive issue civil...  |  Read More

Stein, Michel
Michel R. Stein

Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Toscher, Steven
Steven (Steve) Toscher

Managing Principal
Hochman Salkin Toscher Perez

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video