by Lynam Knott | Sep 20, 2013 | Uncertain Tax Positions
We released the Ferraro 500 today. The Ferraro 500 is a reorganization of the Fortune 500 by the size of the companies’ Unrecognized Tax Benefit reserve (“Tax Reserve”) for uncertain tax positions reported in SEC filings. The 2013 Ferraro...
by Lynam Knott | Jul 25, 2013 | Administration of Whistleblower Claims, Enforcement, IRS Whistleblower Office
I bet that every person reading this blog – people with an interest in the IRS Whistleblower Program – has seen that the IRS has been under fire this summer due to the exempt organization application processing scandal, and is wondering how this situation...
by Lynam Knott | Jul 18, 2013 | Uncertain Tax Positions
From the first mention of Schedule UTP, we felt that taxpayers would provide the minimum information required by the instructions and other published guidance for Schedule UTP. And it looks like this is what has happened. According to an article in Tax...
by Lynam Knott | Jun 11, 2013 | Award Determinations, Guidance, IRS Whistleblower Office, Withholding on Award Payments
Last year we wrote about several welcomed memoranda issued by the IRS Whistleblower Office on June 7, 2013. These memoranda outlined temporary changes and expired a year after issuance. The new memoranda are simply reissuances of the memoranda that were...
by Lynam Knott | Apr 24, 2013 | Administration of Whistleblower Claims, Award Determinations, IRS Whistleblower Office, Judicial Review
Joseph Insinga’s case has been watched closely from the time the petition was filed to see if the Tax Court would assert jurisdiction over a case where the IRS had not issued a formal determination but had allowed the claim to linger, causing a de facto denial...
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