What is an IRS Jeopardy Assessment?

If you are asking the question “What is an IRS Jeopardy Assessment?”, then more than likely you are either someone who (1) is holding on to someone’s money, (2) have gotten into a bit of a rough spot yourself with the IRS, or (3) you are a tax professional …

OVDP transitional streamlined procedures and “willful blindness”

Why are people who are non-willful being categorized as “willfully blind”? Answering this question — it goes to the entire heart of what tax litigation is and IRS administrative practice. And it goes to my absolute frustration when people play attorney with the IRS, instead of actually advocating a position by doing the necessary ground work first.