Moby was the first publicly reported Opt Out of the 2009 OVDP. He has been very generous in sharing his experience, and has been an inspiration to others who have had to battle the fear of what draconian penalties the IRS ‘might’ apply outside of the OVDP. We all believe the IRS FAQ examples are hyperbolic maximums by intention to strike fear into non complying hearts, but until tested, you really don’t know. Moby basically turned down the “in lieu of” OVDP penalty, called their bluff, and won! If you are not familiar with his story, I would strongly encourage you to read it as originally reported on January 25th here and updated on March 10th here . Since the last post, he has been at work on a FOIA request related to IRS FBAR compliance improvement efforts, and asked me to share his findings. What follows is his report. Continue reading
