Joseph C. Bright, member in the Philadelphia office, was recently quoted in The Legal Intelligencer in an article on the state’s and city’s tax amnesty programs. The article notes that tax amnesty programs are rare; rarer still that both Pennsylvania and Philadelphia are holding programs simultaneously. These programs have brought an uptick in business to tax lawyers, including persons with cases on appeal who wonder if they should participate in the amnesty programs. Joe notes that, “For cases on appeal, amnesty really isn’t – no pun intended – very appealing,” because, “essentially you have to give up the case.”
Joe goes on to say that amnesty is only beneficial to those with thin cases. However, that isn’t the case for most people with appeals. “Most people who have appeals pending don’t see an advantage. What they would really like to do is resolve or compromise the issue and you really can’t do that with amnesty. You have to agree with the department’s position.” Joe expects this increase in activity to continue and probably increase as the deadline for each of the amnesty programs draw near.