If the government already has a taxpayer under audit, is investigating a taxpayer, or has his name on a list of taxpayers with secret accounts (for example, one obtained as a result of a John Doe summons to a foreign bank or information from an informant), that taxpayer is not eligible for the OVDP.

FORBES: Taxpayers Who Lost Offshore Account Amnesty Promised Fair Treatment

Illegal aliens as well as Americans are cheating the rest of the taxpayers, with Mothers filing under their Maiden name for perhaps two children, then the Father filing for the same two children as a different tax return under his family name and both receiving child refund tax return dollars.

FORBES: Guest Post: Choosing Where Taxes Go

Taxpayers can no longer rely on the fact that their name is not known to the IRS. With relatively minimal information received from a thief or a shell-company wire transfer, the IRS can extract the intelligence it needs from the Swiss authorities and use it to prosecute the taxpayer.

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