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What is the standard of Willfulness that prevents a taxpayer from entering the Streamlined Program?

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Richard Lehman, JD, LLM
The test for "willfulness" is whether there was a voluntary, intentional violation of a known legal duty. A finding of willfulness must be supported by evidence of willfulness. The burden of establishing willfulness is on the Internal Revenue Service and if is determined that the violation was due to reasonable cause, the willfulness penalty should not be asserted.
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