Welcome to Chamberlain Hrdlicka's Tax Blog where we provide news and analysis of current legal issues facing tax practitioners.
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Well for starters, the IRS won’t be very happy! Beyond that, the IRS has several avenues it can pursue.
In extreme situations, such as where a taxpayer owes a considerable sum of money and has not filed for several years, the IRS may consider pursuing criminal liability under I.R.C. § 7203, which makes it a misdemeanor to “willfully” fail to file a Federal Income Tax Return. This is rarely applied unless a pattern of three consecutive non-filing years are present, but potentially any single willful failure to file could result in this prosecution. There is a six-year statue of ...


