Law Commons^™

The Irs’S Voluntary Disclosure Program: Need For Codification, Jay A. Soled

Georgia State University Law Review

For more than a century, the Internal Revenue Service (IRS) has had a voluntary disclosure program in place. Its purpose is to coax into tax compliance those wayward taxpayers who have committed criminal acts or have been remiss in fulfilling their civic tax-filing obligations. Historically, the voluntary disclosure program has had to strike a difficult balance between being attractive enough to entice tax scofflaws to participate and not being too attractive lest ordinary taxpayers feel that their compliance efforts were for naught.

A unique feature of the voluntary disclosure program is that it is entirely administrative in origin. The commissioner …