## Q35 key (Account Before Bank List Arrives)

1. Unreported income is $300,000. At 30 percent, back tax is $90,000; with $12,000 interest, the base is $102,000. Missed: every path begins from the wrong amount.
2. Voluntary disclosure adds a 20 percent tax penalty of $18,000 and an 18 percent balance penalty of $108,000. Total is $228,000, with no criminal referral for disclosed conduct. Missed: the program is priced incorrectly.
3. The nonwillful procedure would cost $90,000 + $12,000 + $30,000 = $132,000, but Priya cannot truthfully certify nonwillfulness given the false taxpayer form, banker exchange, annual denials, and admitted knowledge. Missed: counsel recommends a cheaper path that creates a separate false-statement offense.
4. Full detected civil cost outside a program is $90,000 tax + $12,000 interest + $67,500 fraud penalty + $240,000 offshore penalty = $409,500. Missed: the downside is understated by hundreds of thousands.
5. Quiet-return expected monetary cost is 0.70 x $409,500 + 0.30 x $102,000 = $317,250. Conditional criminal-referral probability is 18 percent if detected, or 12.6 percent unconditional under the supplied branch probabilities. Missed: quiet filing is presented as amnesty.
6. No-action expected two-year monetary cost is 0.60 x $409,500 = $245,700. Conditional referral is 30 percent if detected, or 18 percent unconditional under the supplied branches. Its monetary expectation is lower than quiet filing but $17,700 higher than the $228,000 program. Missed: arithmetic reverses the actual comparison or ignores the criminal tail.
7. Eligibility can vanish before twelve days if the bank transmits early. Waiting has asymmetric downside because contact or identity transfer permanently closes the no-referral path. Missed: the client treats the stated schedule as a guaranteed grace period.
8. Recommend immediate truthful voluntary disclosure, with rapid financing for the $228,000 fixed cost and complete account reconstruction. Do not use the nonwillful certification or quiet returns. Missed: Priya trades a fixed civil resolution for greater expected cost and meaningful criminal risk.