SOURCE: Marks Paneth & Shron LLP

Marks Paneth & Shron LLP

April 28, 2010 10:10 ET

Marks Paneth & Shron Director and Former IRS Special Agent Speaks to "Tax Analysts" Magazine on Voluntary Disclosure Program and What Taxpayers' Concern Should Really Be

Accept Penalty or Challenge With an Audit?

NEW YORK CITY, NY--(Marketwire - April 28, 2010) -   David Gannaway, MBA, CFE, CAMS, EA, a former IRS special agent with the Criminal Investigation Division who is now a Director in the Litigation and Corporate Financial Advisory Services Group at New York accounting firm Marks Paneth & Shron LLP, has been featured in an article published by Tax Analysts discussing his in-depth perspective on why it might be advantageous for US taxpayers who enrolled in the IRS's voluntary disclosure program to challenge the IRS through an audit.

In the article, Mr. Gannaway explains:

  • Why IRS challenges may exist due to the heavy volume, and perhaps unanticipated, amount of program applications received. 
  • How a 5% penalty could replace a 20% penalty through an audit.
  • Ways in which a set IRS penalty has evened the playing field for taxpayers.
  • Why proving to the IRS that taxpayers' actions were not willful is key to lowering monetary penalty. 

The full text of the article can be found in the Marks Paneth & Shron Library (

To speak with David Gannaway about current tax enforcement issues, please contact Itay Engelman of Sommerfield Communications at 212.255.8386 or via email at

About Marks Paneth & Shron

New York City-based accounting firm Marks Paneth & Shron LLP (MP&S) has a team dedicated to offering services for US taxpayers disclosing foreign accounts at UBS AG and other foreign banks. The firm has extensive experience in working with high-net-worth individuals and international tax issues, as well as in forensic accounting, litigation support, and negotiating with government agencies. For more information please visit

About David Gannaway

David Gannaway, MBA, CFE, CAMS, EA is a Director in the Litigation and Corporate Financial Advisory Services Group at Marks Paneth & Shron LLP. In this role, he provides comprehensive litigation consulting services encompassing the areas of forensic accounting, civil income tax controversies and criminal income tax investigations, complex white collar fraud investigations, and anti-money laundering.

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