Tax Procedure Whistleblower Claims

Whistleblower Using Public Information Cannot Remain Anonymous

We have previously written about the court’s position that serial whistleblowers, those who submit more than one whistleblower claim with the IRS, cannot remain anonymous when litigating the right to their whistleblower claims.  In Whistleblower 7208-17 v. Commissioner, T.C. Memo. 2018-118, the court confirms that this extends to those who use public information to submit […]

Tax Procedure Whistleblower Claims

Freedom of Information Act Reaches Whistleblower Documents

Since its inception, the IRS’s process for paying whistleblower claimants has been widely criticized. Setting aside these criticisms, there have been a number of developments that would-be informants have to consider before submitting IRS Whistleblower claims. The recent Montgomery v. Internal Revenue Service, No. 17-918 (JEB) (Dist. D.C. 2018) adds another factor to consider. Facts […]

Tax Procedure Whistleblower Claims

Court Says Serial IRS Whistleblower Claimant Cannot Remain Anonymous

In Whistleblower 14377-16W v. Commissioner, 148 T.C. 25, the U.S. Tax Court concluded that a whistleblower claimant could not remain anonymous when litigating his claim in court. This case is one all whistleblowers should read and fully understand as it could result in their identity being made public. The Facts The abbreviated facts are as […]

Tax Procedure Whistleblower Claims

IRS Whistleblower Claimants May Be Entitled to Larger Awards

In Whistleblower 11099-13W v. Commissioner, 147 T.C. 3, the court indicated that it may rule on the issue of whether (1) a whistleblower claim can include tax collected in years after the years of the whistleblower claim and (2) the claim can include tax collected due to changes initiated by the taxpayer as a result of […]

Tax Procedure Whistleblower Claims

IRS Guidance on Whistleblower Informant Program

The IRS whistleblower program allows taxpayers to obtain payment from the IRS for providing information about alleged tax wrongdoing by other taxpayers.  How the IRS has administered the program has drawn criticism from politicians, taxpayers, and others.  The IRS’s recent guidance aims to address these criticisms.  It provides a three-step process for handling whistleblower claims: 1. […]

Tax Procedure Whistleblower Claims

Congress Works on the IRS Informants Reward Program

The Tax Relief and Health Care Act of 2006 provides a lot of new tax procedure provisions, such as the Section 6702 frivolous “tax submissions” penalty. This Act also set out a number of changes related to the ineffective and poorly administered (according to the U.S. Treasury Inspector General for Tax Administration) IRS informants reward […]

Tax Procedure Whistleblower Claims

IRS Looks At Improving Informants Rewards Program

One would think that the IRS using paid informants to identify compliance-challenged taxpayers would generate some controversy. But it really hasn’t. As a new TIGTA audit report reveals, the IRS’ Informants Rewards Program hasn’t generated much controversy because the program has been so poorly administered. About the IRS Whistleblower Program The informant process begins when […]