Posted by: Steven Toscher | July 14, 2025

A Step Forward for Voluntary Disclosure: IRS Agrees to Remove Willfulness Checkbox from Form 14457 and Potentially Open the Program to Income Derived from Sale of Marijuana by Steven Toscher, Michel R. Stein and Philipp Behrendt

In a rare and welcomed victory for taxpayer rights and administrative fairness, the IRS has agreed to remove the willfulness checkbox from the next version of the Form 14457—the application form for the Voluntary Disclosure Practice (VDP). In addition, the program will make allowances not to preclude income derived from marijuana sales by changing its definition of illegal source income. 

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For more information contact Steven Toscher at toscher@taxlitigator.com

For more information, please contact Michel R. Stein at stein@taxlitigator.com

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

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