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Tax Compliance, IRS Voluntary Disclosure and Other Domestic Failures

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Charle Butler
Charle Butler
2021-03-12
Verified
I was hesitant to hire the Spodek Law Group. I read reviews and knew they have a great reputation. However, I thought I would spend money and not see or speak to my attorney. From the beginning to end of my case Todd and the entire staff were available and willing to help. We worked towards and end result that was way above my expectation and Todd delivered. I am forever grateful for patience and long days and night spent working on my case. Thanks Todd and the entire team!
Mesonista parsons
Mesonista parsons
2021-03-05
Verified
My attorney at Spodek was Abigail. She was very knowledgeable and helpful with all my questions and concerns, as well as responsive. Her fees are affordable and Abigail took the time to make sure I understood everything relating to my case. I highly recommend Abigail and will request her services in the future.
debabrata chakraborty
debabrata chakraborty
2021-03-03
Verified
Todd A Spodek is the experienced and best criminal lawyer at USA. He is very professional and always respond on time. Alex also very cooperative and always help me. They took care me and my problem like family member. I am 100% satisfied for their professional service. My result was unexpected and amazing. They dismissed my case. I am really grateful to them. I will recommend you to go there if you want to solve your problem. I wish all the best for them.
Asata Hendricks
Asata Hendricks
2021-03-02
Verified
Truly appreciate the work the guys did!. Exceptional team & I know they care about each and everyone of their clients. I am super thankful to be referred to Spodek Law Group and I am grateful Todd & Alex were able to work diligently to achieve an outcome I am pleased with. Despite COVID they stayed on top of things and kept me informed every step of the way. Very thankful.
Mike Moroff
Mike Moroff
2021-02-26
Verified
I'm very satisfied with the services rendered by Todd, Alex and Mary Lou. I whole heartedly recommend Spodek Law Group . I've worked with and have retained other attorneys in the past with Todd's firm being the cream of the crop for many reasons. A very serious legal matter was resolved after a year's hard work and effort. Todd expertly guided me through the process and was able to navigate and make the good journey bearable as well as successful. Mary Lou initially provided excellent assistance before referring my case to Todd. Alex's support was effective and timely. The customer portal (MyCase) is an invaluable communication tool that also kept track of my case. Various aspects of my case were explained and there were several options provided but I made the final decision of how the case would be handled. The legal fee was reasonable considering the effort and amount of work plus it was a flat fee regardless of the length of time required to conclude my case. Todd made himself available to me and we had many scheduled meetings to go over the progress and to discuss the next steps. I felt more confident after many discussions with him. You will not go wrong choosing Spodek Law Group for legal matters.
Josh Katz
Josh Katz
2021-02-24
Verified
Being that it was the first time that I was in need of an attorney, I was afraid and hesitant and knew I needed the absolute best. It is beyond understood why Spodek Law Group has a reputation of being the top, if not the best law firm in New York. Alex and Abigail were there every step of the way even at the most unconvenient hours. I could not have asked for more. They are extremely good at what they do and they delivered much much more than just winning my case. A big thank you to Alex and Abigail for all the guidance and counseling and their upmost loyal support that extended far more than just legally. If you need the absolute best than don't hesitate to hire Spodek Law Firm.
L.C.
L.C.
2021-02-24
Verified
I cannot tell you how thankful I am to Todd and Alex for their hard work and dedication to my case. I had never been in any trouble before but I had an unfortunate event occur and in the midst of COVID-19 at that therefore I knew I needed a team that was dedicated to my success. Today- my case has been finalized and I’m walking away with no record and can continue life as a mother and a Grad student worry free. I cannot express enough gratitude for their assistance.
AnnMarie Soliman
AnnMarie Soliman
2021-02-23
Verified
I received a summons and called Spodek law group for a free consultation. Alex took my call and was very quick and responsive. He was available anytime through multiple platforms and very reassuring when needed. They are extremely organized and thorough. They got my case dismissed! I’m very grateful. Thank you Alex and Todd!


Tax Compliance, IRS Voluntary Disclosure and Other Domestic Failures

Tax Compliance, IRS Voluntary Disclosure and Other Domestic Failures

You diligently paid your taxes for years, satisfying all the IRS’ disclosure or reporting obligations – or so you thought. Or maybe you were actually deliberately understating your tax filings. In truth, the U.S. Tax Code is complex and impossible to fully understand without careful study and consideration. That said, the complexity of the code itself is merely the starting point of the possible troubles. A full and thorough understanding of all obligations can only be achieved after a meticulous review of case law, IRS polies and guidance, and other secondary sources. Because of this, numerous taxpayers come to depend upon the advice and guidance of tax professionals.

Nevertheless, in spite of the taxpayer’s reliance on a professional, it is still the taxpayer who is responsible or held civilly and criminally liable for any willful misstatement or omission that may appear in his or her tax filing history.  Moreover, consider that tax returns get filed under the penalty of perjury. By the time a taxpayer finally discovers that he or she has failed to meet certain obligations, he or she might already be in peril of years of non-compliance that can result in significant penalties, interest, fines, and – depending on conduct – the possibility of a criminal tax investigation and criminal tax penalties.

If the IRS Hasn’t Noticed My Tax Non-Compliance Over Past Years, Why Would They Notice it Now?

A range of changing circumstances and other reasons that explain why tax compliance failures including non-disclosure of accounts, assets, and sources of income can quickly become a pressing concern even in cases where you have reason to believe that you “got away with it”. Consider the following scenarios:

In the wake of the breakup of a marriage, one of the ex-spouses hires a forensic accountant for the divorce proceedings. The forensic accountant finds tax fraud by the other spouse. With this information, in hand, the ex threatens to disclose this information to the IRS and trigger a criminal investigation in an attempt to extort a bigger divorce settlement.

Someone who owns a rapidly growing business discloses a second set of books to a potential buyer. Unexpectedly, the potential buyer threatens that he or she will disclose this to the IRS and relevant state agencies in order to leverage a lower acquisition price.

The owner of a company is targeted for an audit by state regulators. The owner is concerned that the federal acts of fraud or other wrong-doing will be discovered in the audit.

Voluntary Disclosure Could Provide a Degree of Insulation Against any Criminal Penalties

A well filed and legally sufficient Voluntary Disclosures given to the IRS can furnish a taxpayer with a level of protection against criminal charges relating to his or her disclosed non-compliance. Simply put, the taxpayer will not be recommended for criminal prosecution. For efficient administration of the tax system, the IRS has long held that taxpayers who step forward voluntarily, make a full and complete disclosure, and agree to remit a penalty can avoid criminal penalties, including prison. However, the kind of disclosure that should be made should be reliant upon the taxpayer’s risk.

Be warned: A voluntary disclosure should never be done without the guidance of experience criminal tax defense counsel and the use of a Kovel Accountant to protect the taxpayer’s constitutional rights, attorney client privilege and the attorney’s work product!\.

Actually, the U.S. tax system depends heavily, at least initially, on self-reporting by taxpayers (self-assessment). If the tax system was not initially based on self-assessment, the present levels of IRS staff would make the tax system unworkable. To further encourage taxpayer compliance, even after a period of purposeful compliance failures, the IRS has held a policy that confers certain benefits on individuals who voluntarily disclose their past acts or omissions of non-compliance, file accurate returns for the affected years still open to criminal statue (generally 5 years), and who remits a full payment or goes into an approved payment plan. As long as the disclosure is voluntary, accurate, complete, and legally sufficient, the IRS has a policy of holding back from recommending these taxpayers for criminal prosecution.

When Am I Able to Make a Voluntary Disclosure?

A Voluntary Disclosure must be timely to be effective. Should the taxpayer be reasonably aware of an investigation or facts and circumstances suggesting that the government has already uncovered the non-compliance that is the subject of the disclosure is not timely. Voluntary disclosures are considered to be timely when they are made:

  1. Before the commencement of an IRS examination or prior to IRS notification to the taxpayer of an upcoming audit or examination.
  2. Before any third-party whistle-blower supplies information regarding fraud or other noncompliance to the IRS.
  3. Before the IRS acquires information regarding noncompliance from other sources.

As such, it is important to be timely when considering a Voluntary Disclosure. Nevertheless, taxpayers must not be hasty in their decision to file for Voluntary Disclosure since there are certain scenarios, such as illegal source income, where such a disclosure would be ineffective. Furthermore, taxpayers need to engage in a careful analysis of their behaviors and circumstances and in what ways they may be interpreted by an IRS examiner. Taxpayers should also consider whether a “noisy” or “quiet” disclosure is more appropriate for their unique tax situation.

What is the Difference between Noisy Disclosure and a Quiet Disclosure?

A voluntary disclosure is considered a noisy one because the criminal investigation division is contacted at the beginning of the process.   A quiet disclosure would simply involve filing 5 years of amended returns at the client’s normal service center.  The advantage of this latter method is that the taxpayer could be sheltered from the costs and stress of submitting to an audit that ordinarily comes on the heels of a loud voluntary disclosure.    The disadvantage of a quiet disclosure is that it could be viewed as an admission of guilt without the expected pass on criminal prosecution that follows a loud disclosure.  The critical decision to do a loud or quiet disclosure should not be made without experienced criminal tax defense attorneys.

Our Experienced Tax Professionals Will Guide You Through the Voluntary Disclosure Process

The seasoned, hard working tax attorneys and Kovel CPAs at our law firm can help concerned taxpayers understand what their options are. As soon as we have explained the process and the potential opportunities to mitigate the circumstances to the taxpayer, our experienced tax attorneys can take care of every step of the process. To schedule a consultation with a tax lawyer call us today!


Charle Butler
Charle Butler
2021-03-12
Verified
I was hesitant to hire the Spodek Law Group. I read reviews and knew they have a great reputation. However, I thought I would spend money and not see or speak to my attorney. From the beginning to end of my case Todd and the entire staff were available and willing to help. We worked towards and end result that was way above my expectation and Todd delivered. I am forever grateful for patience and long days and night spent working on my case. Thanks Todd and the entire team!
Mesonista parsons
Mesonista parsons
2021-03-05
Verified
My attorney at Spodek was Abigail. She was very knowledgeable and helpful with all my questions and concerns, as well as responsive. Her fees are affordable and Abigail took the time to make sure I understood everything relating to my case. I highly recommend Abigail and will request her services in the future.
debabrata chakraborty
debabrata chakraborty
2021-03-03
Verified
Todd A Spodek is the experienced and best criminal lawyer at USA. He is very professional and always respond on time. Alex also very cooperative and always help me. They took care me and my problem like family member. I am 100% satisfied for their professional service. My result was unexpected and amazing. They dismissed my case. I am really grateful to them. I will recommend you to go there if you want to solve your problem. I wish all the best for them.
Asata Hendricks
Asata Hendricks
2021-03-02
Verified
Truly appreciate the work the guys did!. Exceptional team & I know they care about each and everyone of their clients. I am super thankful to be referred to Spodek Law Group and I am grateful Todd & Alex were able to work diligently to achieve an outcome I am pleased with. Despite COVID they stayed on top of things and kept me informed every step of the way. Very thankful.
Mike Moroff
Mike Moroff
2021-02-26
Verified
I'm very satisfied with the services rendered by Todd, Alex and Mary Lou. I whole heartedly recommend Spodek Law Group . I've worked with and have retained other attorneys in the past with Todd's firm being the cream of the crop for many reasons. A very serious legal matter was resolved after a year's hard work and effort. Todd expertly guided me through the process and was able to navigate and make the good journey bearable as well as successful. Mary Lou initially provided excellent assistance before referring my case to Todd. Alex's support was effective and timely. The customer portal (MyCase) is an invaluable communication tool that also kept track of my case. Various aspects of my case were explained and there were several options provided but I made the final decision of how the case would be handled. The legal fee was reasonable considering the effort and amount of work plus it was a flat fee regardless of the length of time required to conclude my case. Todd made himself available to me and we had many scheduled meetings to go over the progress and to discuss the next steps. I felt more confident after many discussions with him. You will not go wrong choosing Spodek Law Group for legal matters.
Josh Katz
Josh Katz
2021-02-24
Verified
Being that it was the first time that I was in need of an attorney, I was afraid and hesitant and knew I needed the absolute best. It is beyond understood why Spodek Law Group has a reputation of being the top, if not the best law firm in New York. Alex and Abigail were there every step of the way even at the most unconvenient hours. I could not have asked for more. They are extremely good at what they do and they delivered much much more than just winning my case. A big thank you to Alex and Abigail for all the guidance and counseling and their upmost loyal support that extended far more than just legally. If you need the absolute best than don't hesitate to hire Spodek Law Firm.
L.C.
L.C.
2021-02-24
Verified
I cannot tell you how thankful I am to Todd and Alex for their hard work and dedication to my case. I had never been in any trouble before but I had an unfortunate event occur and in the midst of COVID-19 at that therefore I knew I needed a team that was dedicated to my success. Today- my case has been finalized and I’m walking away with no record and can continue life as a mother and a Grad student worry free. I cannot express enough gratitude for their assistance.
AnnMarie Soliman
AnnMarie Soliman
2021-02-23
Verified
I received a summons and called Spodek law group for a free consultation. Alex took my call and was very quick and responsive. He was available anytime through multiple platforms and very reassuring when needed. They are extremely organized and thorough. They got my case dismissed! I’m very grateful. Thank you Alex and Todd!

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Testimonials

Spodek Law Group have offered me excellent support and advice thru a very difficult time. I feel I've dealt with someone who truly cares and wants the best outcome for you and yours. I'm extremely grateful for all the help Spodek Law Group has offered me. I can't recommend them enough.

~ David Bruce

Spodek Law Group was incredibly professional and has given me the best advice I could wish for. They had been helpful and empathetic to my stressful situation. Would highly recommend Spodek Law Group to anyone I meet.

~ Rowlin Garcia

Best service I ever had. Todd is absolutely class personified. You are in the safest hands with spodek. They have their clients interest in mind.

~ Francis Anim

Spodek Law Group

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We provide superior service, excellent results, at a level superior to other criminal defense law firms. Regardless of where your case is, nationwide, we can help you.



Hear From Our Clients

"Spodek Law Group have offered me excellent support and advice thru a very difficult time. I feel I've dealt with someone who truly cares and wants the best outcome for you and yours. I'm extremely grateful for all the help Spodek Law Group has offered me. I can't recommend them..."

David Bruce

"Spodek Law Group was incredibly professional and has given me the best advice I could wish for. They had been helpful and empathetic to my stressful situation. Would highly recommend Spodek Law Group to anyone I meet."

Rowlin Garcia

"Best service I ever had. Todd is absolutely class personified. You are in the safest hands with spodek. They have their clients interest in mind."

Francis Anim
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