Original commentary from Segal, Cohen & Landis (SCL). Updated September 13, 2026. This discussion provides historical context for the IRS announcement of February 29, 2024; it does not describe a newly announced enforcement campaign.
A missing return deserves a deliberate response
In February 2024, the IRS announced an initiative covering more than 125,000 instances of unfiled returns associated with high-income taxpayers. The agency said third-party records, including wage and information returns, indicated income even where no corresponding tax return had been filed. Those were filing cases, not necessarily 125,000 different people.
For a taxpayer receiving a notice, the practical question is specific: which year does the IRS believe is missing, and what records establish the correct filing position? A headline about enforcement cannot answer that question. Neither can an income figure viewed without deductions, payments, filing status and the rest of the return.
Start with the notice and a year-by-year record
Keep the complete notice and its envelope, identify the response deadline, and check whether the return was filed under the correct taxpayer identification number. If you believe it was filed, gather a copy and proof of submission. If it was not, organize income records, business books, prior returns and payment records by year. A clear timeline helps distinguish a missing filing from a processing or account issue.
We recommend addressing both the paperwork and the explanation for the gap. Missing records, overseas reporting, business changes and concerns about earlier filings may require different responses. Do not assume that the same solution fits every unfiled year.
Filing and paying are separate questions
The IRS explained that unresolved nonfiling cases can progress to additional notices and enforcement, including a substitute return prepared from information available to the agency. Such a return may omit deductions or other items that require the taxpayer's records. Preparing an accurate return and evaluating how to address a balance are related but separate tasks.
A useful plan identifies the required filings, any existing assessments, payment resources and response deadlines. Where a balance cannot be paid immediately, the available collection options depend on the taxpayer's circumstances and applicable requirements. No settlement amount can be promised from the size of the debt alone.
Get advice before choosing a disclosure route
Where the facts suggest deliberate noncompliance or other criminal exposure, obtain legal advice before sending an explanation or selecting a disclosure procedure. Streamlined offshore procedures and the IRS Voluntary Disclosure Practice have different purposes and eligibility rules. Neither should be treated as a general-purpose shortcut for missing returns.
SCL can review the notices, filing history and supporting records, then explain the next steps suited to the matter. Learn about unfiled tax return representation or request a consultation.
Source and context
This commentary is based on the IRS's own historical announcement, IR-2024-56, February 29, 2024. It replaces the third-party news reproduction previously available at this URL. It is general information, not an assessment of any reader's individual tax position.
Have questions about this topic? Talk to an IRS attorney today.
Segal, Cohen & Landis, P.C. — Beverly Hills. Serving clients nationwide.
Original commentary by Segal, Cohen & Landis.