https://www.taxconnections.com/taxblog/an-analysis-of-tax-settlement-programs-as-amnesties-why-irss-offshore-voluntary-disclosure-settlement-programs-posed-risks-to-voluntary-compliance-part-2-of-3/
An Analysis Of Tax Settlement Programs As Amnesties - Why IRS’s Offshore Voluntary Disclosure Settlement Programs Posed Risks To Voluntary Compliance (Part 2 of 3)