This is a thought experiment regarding the Miranda Rights and how they might properly apply to OVDI and FBAR. If a big boy says to a little boy at school, “Give me your lunch money or I will clobber you on your way home today.” The teacher sees the little boy hand the money over to the big boy. The big boy says to the teacher: “He gave it to me voluntarily.”
UPDATE: Steven J. Mopsick, 30 year IRS Veteran has responded.