Monday, September 8, 2014

SNL or tax lawyer quotes with regards to the IRS and OVDI/P

1. “For most of these folks (taxpayers)  this is the hill they may choose to die on as the most significant economic event (FBAR penalties) of their entire lives. “… meaning I am not a professional fearmonger but please send me your retainer asap.
2. "You can relax now - we got you covered "... meaning please leave me alone now until you need to replenish your retainer.
3.  " ...the IRS was going to fight a lot harder to do better than the 5% penalty.... meaning I am short on my monthly OVDP client annuity revenue.
4. " OVDI/P and FS2011-13 are all the same..." .....meaning I really have no clue what I am talking about.
5. "...  I (Jack Townsend) will strive to serve my intended audience in moderating the emails " .... meaning I am not that liberal and short on cases because my teaching job pays poorly and my country club membership just expired.
6. ..."this is not a tax policy blog but a tax crimes blog ".... meaning I don`t care or I am just too stubborn to admit who is right or wrong here as long as I am selling some consultation time to as many minnows as possible .
7. ...." a person is non-willful if he "isn't really worried about being prosecuted.".... meaning will you step into my parlor ? said the spider to the fly.
8. .... "The concept of willfulness is well documented in the case law"..... meaning we're depending on the practitioners (CPAs and tax lawyers) to help the taxpayers work their way through what the risk is of criminal prosecution and significant penalties but of course we have no conflict of interest with the extra compliance cost. 
9.  ..... "we need the flexibility to go over bottom level IRS workers' heads, be creative with the many alternatives options available to us, involve other functions on a formal or informal basis, or use any tactic formal or informal techniques if it means putting forth a vigorous defense of your case with the IRS..." meaning if I cannot convince my client, confuse him with regards to his monthly billing statement.
10.  ...."we need to dictate to bottom level clerks how they should categorize your case on the Byzantine and labyrinth-like interlocking relics of IRS "computers"....meaning please don`t be alarmed if after 12 month we still don`t understand your case and facts or circumstances.
11. ..."a practitioner has a first responsibility to their client and not the IRS"... meaning in theory, theory and practice are the same. In practice, they are not.
12. ...."I (Jack Townsend) do understand the different nuances and shades of grey when defending Homelanders vs. Expats with regards to "offshore accounts".... meaning I have not yet represented an expat during OVDI or OVDP or in any opt out for that matter.

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