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The real question in my mind is "was there an intent to defraud or avoid". Can he prove there was no intent? Did he truly underpay?
I was audited a couple of decades ago. At the end of the audit they cut me a check. They (the IRS personnel) were very nice during the whole thing, very low key.
Then the IRS audited me a couple more times to see if they could recoup any of that money. It was pretty much my own fault because I forgot I needed to update the refund amount on the following year return so I could pay a bit more additional taxes on the following year return.
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David
'83 SC Targa (sold  ) MANLY babyblue honda '00 F250 7.3L (MINE!)
'15 F250 Gas (Her Baby) '95 993 (sold )
I don't take scalps. I'm civilized like white man now, I shoot man in back.
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