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Florida Tax Review

Abstract

It is the purpose of this article to suggest that there be incorporated in the tax package a comprehensive federal tax amnesty program to secure additional tax revenues which will not otherwise be recovered by the government. Although a federal tax amnesty program has often been discussed, the Internal Revenue Service has consistently opposed the adoption of such a program. In light of the pressing need for more revenue and anticipated significant increases in federal expenditures to fund a comprehensive health program, the matter of a tax amnesty program deserves a full review. If we are to reinvent the government as the President has proposed, we must be able to review prior policy conclusions to see whether they remain appropriate from the perspective of current conditions.

The sections set forth below discuss (1) the "tax gap"; (2) the recently announced nonfiling program of the Internal Revenue Service; (3) the administrative enforcement options available to the Internal Revenue Service; (4) an overview of a comprehensive tax amnesty program; (5) the traditional response of the Internal Revenue Service to a proposed amnesty program; and (6) a proposed model for a comprehensive tax amnesty program.

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