VCP applications increase audit risk?

[JWK]

Has anyone seen data or even heard anecdotal evidence that filing VCP applications increases a plan's chance of being audited? Does the IRS even maintain data showing the number of applications a particular plan sponsor has filed?

[John Feldt ERPA CPC QPA]

Well, according to IRS officials at a conference (fall 2006), they want to keep the integrity of the EPCRS program in tact. They stated that the only time they would ever turn over a closed unresolved VCP case to their auditors would be for an egregious case. They also stated that (as of the date of that conference) they only had a few (less than a dozen?) cases that were closed as unresolved, and none of those were turned over to their auditors.

[Just Me]

Joyce Kahn has said that if the IRS were to trigger audits based on VCP filings, it would have a "chilling effect" on EPCRS generally. So no, they don't do this. I have not seen any pattern of audits filing VCPs after having done a number of VCP filings.