In this article, IRS attorney Robert E. McKenzie discusses the IRS audit system.
From the Government’s perspective, statutes of limitation restrict the taxpayer’s right to claim a refund of
overpaid tax or initiate litigation to obtain a refund. From the taxpayer’s perspective, statutes of limitation
prevent the IRS from collecting a deficiency in tax or beginning a civil or criminal case. In short, statutes of
limitation provide a date of finality after which actions taken by the IRS or the taxpayer cannot be disturbed by
the other party
IRS will step up its efforts to find Americans utilizing tax haven banks. Since September 11 the U. S. Financial Crimes Enforcement Network has developed a coordinated program to find money laundering, foreign banking activity, and tax evasion. In most white collar crime cases the Justice Department offers plea bargains to individuals like Birkenfeld in return for cooperation in charging others involved in illegal activity. Therefore with increased resources being allocated to seeking out foreign bank activities by Americans we can anticipate will the first of many bankers who cooperate to reduce their potential jail time.