The Maze Streamlined Litigation case — our take
Three retired taxpayers had undisclosed offshore accounts. All three of them made innocent mistakes. They were frightened into entering into the 2012 IRS Offshore Voluntary Disclosure Program (OVDP) where they would have to pay a 27.5% penalty on account value. The IRS then changed the rules to allow for a lower penalty. These elderly tapaxayers attempted to have this 5% penalty applied to them, but were frustrated.