12/26/2002: How Voluntary Compliance Programs Began at the IRS (Steve Leventhal, J.D. LL.M. Taxation)Excerpt: "Here is the background to the 'how and why' employee plans voluntary compliance started.... The attorneys in my group and I came to understand that the real-world ramifications of the technical position calling for disqualification was no longer realistic and quite often unfair. Disqualification often led to adverse tax consequences to the employer, participants, and trust, that were frequently totally disproportionate to the nature and type of plan failure(s)."
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