Form 14457, Step by Step: How a Voluntary Disclosure Moves Through the IRS

Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, is the doorway into the IRS Criminal Investigation Voluntary Disclosure Practice. Every voluntary disclosure must go through it. IRM 9.5.11.9.1 says taxpayers "must utilize Form 14457" to participate.

This guide walks through the process as described in IRM 9.5.11.9 (revised November 19, 2025), the civil procedures in IRM 4.63.3.18 (revised April 21, 2025), and the IRS VDP web page last updated July 20, 2026. The IRS has proposed changes to the process, noted below, that had not been finalized as of that page. It is general information. A voluntary disclosure is an admission of willful conduct, signed under penalties of perjury. It should be prepared with a lawyer.

Before you file anything

Two threshold questions come first, and both are legal judgments.

Is the conduct willful? The VDP is for taxpayers with criminal exposure due to willful violations. If it was not willful, the IRS says to consider other options, like amended or delinquent returns. See willfulness in criminal tax cases.

Is it still timely? A disclosure must be received before the IRS opens an examination or investigation, receives third-party information about you, or acquires related information through an enforcement action. See voluntary disclosure timeliness.

The IRS also warns against applying before you are ready. Its VDP FAQs say: "If you don't have all required documents for the VDP, please do not apply for Part I," because missing documents delay the application and "may result in your removal from the program."

Step one: Part I, the preclearance request

Part I is about eligibility. IRM 9.5.11.9.1 says preclearance "involves supplying key information for CI to determine if the taxpayer is eligible to make a voluntary disclosure, including establishing if the unreported income is from legal sources and that the timeliness requirements are met."

Part I includes the disqualifying questions listed in IRM 9.5.11.9.4: whether the IRS has notified you, your spouse, or related entities of an examination or criminal investigation; whether any of you are under criminal investigation by the IRS or any law enforcement authority; and whether any of you have income from illegal activity. A "yes" may make you ineligible.

If the disclosure is made through a representative, the IRS VDP page says a separate Form 2848 is required for each individual taxpayer and entity entering the program. The IRS will not accept a combined list on one form.

Related entities matter here too. IRM 4.63.3.18.1 says related entities identified on an individual disclosure must check the box on Part I indicating that the entity is also making a voluntary disclosure to be eligible for VDP terms.

Under the current procedures, the IRS VDP page says Part I is submitted by fax to the number listed on that page. All voluntary disclosures are processed by a CI headquarters unit, which IRM 9.5.11.9.2 identifies as CI-Headquarters-Global Operations Policy and Support.

Step two: the preclearance letter

CI reviews Part I for completeness and timeliness. If the taxpayer meets the definition of timely and the request is complete, IRM 9.5.11.9.2 says CI issues a preclearance letter advising the taxpayer to submit Part II within 45 days. CI provides written notification either way. Preclearance comes with a case control number, and Part II cannot be submitted without it.

The IRS page is careful about what preclearance means: it "determines your eligibility for the practice but does not guarantee preliminary acceptance."

Step three: Part II, the application, within 45 days

The clock starts with the preclearance letter. IRM 9.5.11.9.1 says Part II must be submitted within 45 days, and "one additional 45-day extension may be granted upon written request." The IRS FAQ adds that only one extension is granted, and that a taxpayer who cannot meet the extended date should voluntarily withdraw.

Part II is where the substance lives. The manual requires "a narrative, signed under the penalties of perjury by the taxpayer (and their spouse if making a joint disclosure), with specific facts that detail the complete story of the willful noncompliance." The narrative must:

• address the taxpayer's personal and professional background;
• identify all professional advisors who rendered services to the taxpayer from the inception of the noncompliance;
• provide "the whole story with all favorable and unfavorable facts including the entire history of noncompliance from the inception through the present."

A submission without a complete narrative is incomplete. Under IRM 9.5.11.9.1, the taxpayer gets an incomplete letter and 14 days to supplement. If the narrative is still incomplete, CI notifies the taxpayer that the disclosure was not preliminarily accepted.

That narrative is a sworn statement of willful conduct. A false statement as to any material matter on any part of Form 14457 can make the taxpayer ineligible or lead to revocation under IRM 9.5.11.9.4. See false returns under section 7206(1) for why anything signed under penalties of perjury must be accurate.

Timing note: the disclosure period moves with Part II

The civil manual says the disclosure period is measured from the date CI receives Part II, not Part I. IRM 4.63.3.18.3 gives an example: a taxpayer whose 2019 return was on extension listed 2013 through 2018 on Part I, but submitted Part II after the extended due date, so the disclosure period shifted to 2014 through 2019. The period generally covers the most recent six tax years for which the due date has passed.

Step four: preliminary acceptance

If Part II is complete and the research reveals nothing disqualifying, CI issues a Preliminary Acceptance Letter. Under IRM 9.5.11.9.5 and 9.5.11.9.6, CI then transfers the disclosure to a civil unit for processing, and the case is assigned to an examiner, who sends an initial contact letter.

If research reveals potentially disqualifying information, the application is denied with a declination letter.

Step five: the civil examination

This is where the returns, the tax, and the penalties get resolved. Under IRM 4.63.3.18.6 and 4.63.3.18.8:

• The taxpayer should have a complete package ready when the examiner makes contact.
• Signed original delinquent and amended returns go to the assigned examiner, not through normal processing, so the VDP penalty framework can be applied correctly.
• FBARs must be filed electronically, with confirmation and copies provided to the examiner.

The IRS page says you will be required to provide a statement acknowledging your willful failure to comply. The civil manual lists the elements of cooperation, including promptly responding to document requests, providing statute extensions as needed, agreeing to the examiner's adjustments, and paying in full or entering an acceptable full-payment arrangement. Agreed cases can close with a Form 906 closing agreement, which the civil manual addresses in IRM 4.63.3.18.12. See the voluntary disclosure penalty framework.

Revocation

Preliminary acceptance can be taken back. Under IRM 9.5.11.9.7, an examiner can ask CI to revoke it if the taxpayer fails to cooperate fully, and a discovery of materially false statements can lead to revocation and a referral to CI for criminal evaluation. The civil manual says that after revocation, examiners may expand the examination to all years and assert all applicable penalties to the maximum extent.

What the proposed process would change

Under the IRS's December 22, 2025 proposal, taxpayers would electronically submit Form 14457 and, once precleared, receive a conditional approval letter directing them to file all required returns and reports and pay all amounts due within three months, sign a closing agreement waiving statutes of limitations, and agree to the specified penalties. The IRS said not all disclosures would be subject to a full examination. As of the IRS page dated July 20, 2026, the IRS described these as proposed changes.

Keep the representative's role in mind. The IRS VDP page says questions about the status of preclearance or preliminary acceptance go to CI by email, and after preliminary acceptance, to the civil examination contact it lists. Those communications, like the forms, become part of the record.

General information only, not legal advice. Reading this page does not create an attorney-client relationship. Laws and IRS procedures change; the sources cited were reviewed on the date shown above.