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Day: July 11, 2011

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

11 July, 2011

The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure.  Taxpayers who participate in the OVDI, but feel that their

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