It appears that whatever Non-Willful means outside of the OVDP streamline program; it is certainly being applied differently in evaluating a Taxpayer’s ability to transition from the OVDP program into this new 2014 streamline program.
Below I’ve attached two excerpts one from Forbes and one from BNA Daily Tax Report, both verifying that taxpayers who are currently in the OVDP program are having very little success in proving “non-willfulness” during their requests for transition into the new 2014 streamline procedure.
1. Am I Non-Willful Under The OVDP Streamlined Procedures?
Taxpayers recently attempting to transition from the OVDP into the streamlined procedures Read more