Willful Failure to File. President Obama has proposed to upgrade, beginning on December 31, 2012, the willful failure to file a tax return from a misdemeanor to a felony. The proposal would make it a felony to willfully fail to file for three years within any five consecutive years, if the aggregated tax liability is $50,000 or more.

Failure to Comply with E-file Requirements. President Obama has proposed an assessable penalty for failure to comply with e-filing requirements. The penalty would be $25,000 for a corporation and $5,000 for a tax-exempt organization.

National Directory of New Hires (NDNH). The proposed budget would enable the IRS to use the data from the NDNH for general tax administration purposes. These include data matching, verification of taxpayer claims during return processing, preparation of substitute returns for non-compliant taxpayers, and identification of levy sources.

State Tax Adjustments and Statutes of Limitation. The general, three-year statute of limitations for assessment of federal tax liability may prevent the IRS from making an assessment resulting from adjustments to state or local tax liabilities. President Obama has proposed a one-year extension of the statute of limitations from the date on which the taxpayer first files an amended tax return with the IRS reflecting adjustments to the state and local tax return; or a two-year extension from the date the IRS first receives information from the state or local agency under an information sharing agreement between the IRS and state and local agency.