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Hello this is Anthony parent from parent & parent LLP IRS medic and you know one of the common themes I've been mentioning over the years is how complicated the US tax code is and in fact the IRS has a difficulty administering its own laws there's no one in the world that knows everything about tax US taxes including anyone at the IRS and it's very difficult for them to keep track of what's going on in many cases and here is another example that we've ran into and encountered where the IRS isn't aware of what tax payers have filed and let me set up the scenario for you a little bit here years ago it was very common that we would file an offshore voluntary disclosure for people that were haven't reported their offshore accounts and incomes basically everybody sort of fit into the offshore voluntary disclosure program the Oh VDP as it was later the rules were relaxed in 2014 to sort of make them a little bit more fair for everybody one of the OVD p forms out there was something called the preclearance and you filed this preclearance because well look you're following an offshore voluntary disclosure program for a reason and one of those reasons is there could be a criminal investigator a criminal investigation going on so we would file pre clearances in most cases and even in cases where we're pretty sure the client would file a streamlined submission and the reason why is because just because you know some filing streamlined submission is somebody in my opinion and their opinion our staff that somebody who didn't have a real criminal intent they shouldn't have criminal exposure but just because you didn't do anything wrong doesn't mean the IRS investigation unit is going to look at that way so we've submitted hundreds of streamlined disclosures over the years and two of our pre clearances that we sent out came back that the client was under investigation and we talked in both cases to the prosecutor to the US attorney who was assigned the case in both cases because we got there quickly they said okay as long as you're going to do your streamline disclosure that's fine and we're not going to any additional action so the streamlined so filing these preclearance forms for these two clients was incredibly valuable because let me tell you something once that investigation starts you might be innocent you might very well be innocent but they also like to indict your spouse to to put additional pressure on you to plead - guilty and and also finding an attorney who can represent you assuming you have the emotional fortitude to stand up to the the US government is going to cost you hundreds of thousands of dollars and you know to say two years of your life wasted tied up in court and that's why the plea if you look at the the police