Federal case after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than non-willfulness.  This is not surprising because the distinction between willful and non-willful behavior is not clear.  Indeed, because most federal courts have … Continue reading Flint Demonstrates the Risks in Trying to Make a Willful IRS Streamlined Filing Non-Willful