IRS Whistleblower Claims Denied for Inadequate IRS Audit

The Revenue Restructuring Act of 1998 made significant changes to the IRS. One change is that IRS employees cannot be rewarded based on enforcement efforts. This has changed the nature of the relationship between IRS management and IRS employees. For example, IRS auditors report to group managers. Group managers focus mostly on assigning audit cases…

Whistleblower Claim Limited by Sequestration

Whistleblower Claim Limited By Sequestration

We help claimants submit whistleblower claims. But when we receive calls asking for help with whistleblower claims, we do everything we can to dissuade the callers from submitting claims. The IRS’s whistleblower program has been plagued by mismanagement. Cases have long been mishandled by the IRS. Legitimate awards denied. Claimants have to be prepared to…

Whistleblower Cannot Remain Anonymous

The Trade Or Business Requirement For The Sec. 199a Deduction

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…

Freedom of Information Act Reaches Whistleblower Documents

Payments To Foreign Student Studying In U.s. Subject To Tax

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…

Serial IRS Whistleblower Cannot Remain Anonymous

Serial Irs Whistleblower Cannot Remain Anonymous

You would think that an IRS whistleblower could always remain anonymous. That is a fundamental feature of the whistleblower program. 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…

IRS Whistleblower Claimants May Be Entitled to Larger Awards

Irs Audit Adjustments That Change Accounting Methods

The IRS is often gets more from whistleblowers than one may think. Specifically, the IRS may be able to recoup taxes, penalties and interest for other years or related but different issues. There is a question as to whether the whistleblowers who shine the light on these other years or issues should be compensated for…

IRS Guidance on Whistleblower Informant Program

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.…

Congress Works on the IRS Informants Reward Program

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…

IRS Looks At Improving Informants Rewards Program

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…