
Sandra R. Brown was recently quoted in a recent Forbes article by Guinevere Moore, “Confession May Soon Cost Less: IRS Promises Lower Penalties For Voluntary Disclosure,” published October 23, 2026.
The article covers remarks by IRS Chief Tax Compliance Officer and Criminal Investigation Chief Jarod Koopman at the UCLA Extension Tax Controversy Conference, where Sandra Brown interviewed Mr. Koopman who stated that the IRS is “very close” to releasing a revised Voluntary Disclosure Program.
Commenting on the announcement, Ms. Brown explained:
“In an environment where the IRS has faced massive workforce reductions and reorganizations, a shift in this program to a fresh start focus that prioritizes long-term reintegration of non-compliant filers is a clear win-win for tax administration.”

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits. Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases.
For more information, please contact Sandra R. Brown at brown@taxlitigator.com.
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