Taxpayer Advocate Criticizes IRS Implementation of OVDP on Bait and Switch (6/30/11)

The Taxpayer Advocate has issued a Report to Congress on its Fiscal Year 2012 Objectives (6/30/11).

In the Report at pp. xxxiv and xxxv, the Taxpayer Advocate criticizes the IRS's implementation of its statement in the 2009 OVDP that “[U]nder no circumstances will a taxpayer be required to pay a penalty greater than what he would otherwise be liable for under existing statutes.”  The IRS did the old bait and switch on that seemingly clear statement.  The Taxpayer Advocate lays it out pretty well in her report.  The relevant excerpt (with footnotes) is here.  I have cut and paste the relevant excerpt without the footnotes are follows:
Read more »