IRC §6651, IRC §6662, IRC §7122, IRS Fresh Start administrative guidance
Voluntary Disclosure / IRS Fresh Start
IRS resolution requires a strategic approach. Penalty abatement removes first-time or reasonable cause penalties, installment agreements spread payments, and voluntary disclosure programs reduce penalties for coming forward proactively.
Who this may apply to
- Have unfiled tax returns
- Owe back taxes to the IRS
- Received IRS notices or liens
- Need to negotiate payment terms
Strategy connections
Works well with
- Offer in Compromise: Filing compliance and liability resolution may be required before collection alternatives are available.
What could block this
- No willful tax or tax-related noncompliance requiring the practice
- The IRS has already received information about the noncompliance
- The taxpayer is not prepared to cooperate and make a good-faith payment
Professional support
Tax Resolution Specialist / Enrolled Agent
Will represent you before the IRS, negotiate settlements, file back returns, and remove penalties where possible.
Official sources
Reviewed 2026-07-24