This session will explore numerous hazards, opportunities and practical applications of the 2012 OVDP, including a review of numerous technical issues and input for how to address these issues, such as opt-out cases, filing in the formal OVDP versus "Service Center" filings, handling IRS client interviews, and much more. Also included will be a review of challenging client questions with practical examples and how to address those questions with both technical input and practical guidance, plus a segment on assessing whether or not to file in the new streamlined program versus the formal OVDP or the traditional IRS voluntary disclosure practice.