IRS Moves onto Civil Information Document Requests to obtain information concerning Undisclosed Offshore Accounts

Based on what I have seen, it appears the IRS’s next step will be its use of civil Information Document Requests (“IDRs”) being sent to taxpayers that have potential undisclosed accounts.

Specifically, taxpayers may receive a Form 6564, Information Document Request, to secure necessary books, papers, and other data relevant to the IRS examiner’s inquiry into the validity of a tax return.  Normally these IDRs are civil but “watch out” there may be what is referred to as a “parallel investigation” going on in the back ground ( or the CI or Criminal Division of the IRS may be involved or based on the information provided the situation may be forwarded to CI). 

These issues are extremely sensitive and taxpayers should contact an attorney if they receive such an inquiry.