The Internal Revenue Service's tough stance on settling the "Son of Boss" tax shelters matches the call by the IRS Oversight Board for increased compliance funding, as well as the tax gap findings of the National Research Program. Together, they signal a sea change from the kinder, gentler, post-1998 hearings IRS.

The 1998 hearings led to a decline in IRS enforcement activity, resulting in a shelter-friendly climate that encouraged taxpayers to test the waters, according to observers.

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