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Willfulness
So much of the discussion around the IRS amnesty initiatives lies in the concept of “Willfulness”. While nothing here should be construed as legal advice, here are some key points to consider – 31 U.S.C. § 5321 (a)(5)(C)imposes upon any person who “willfully violat[es]” or “willfully caus[es] any violation of … section 5314,” a penalty […]