by Lynam Knott | Oct 10, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review
The Tax Court dismissed a whistleblower’s complaint that challenged the IRS’s decision not to act on the whistleblower’s information. In Raymond Cohen v. Commissioner of Internal Revenue, 139 T.C. No. 12 (October 9, 2012), the Tax Court holds...
by Lynam Knott | Sep 18, 2012 | Administration of Whistleblower Claims, Guidance, IRS Whistleblower Office, Judicial Review
As discussed in an earlier blog post, the Tax Court formally adopted amendments to the Tax Court Rules of Practice and Procedure on July 6, 2012. The amendments rules include Rule 345, which provides that a whistleblower may proceed anonymously by redacting the...
by Lynam Knott | Sep 11, 2012 | Award Determinations, IRS Whistleblower Office, Offshore Assets
Congratulations to Brad Birkenfeld for receiving a $104 million award from the IRS for turning in UBS for their offshore banking practices. Kudos to Steve Kohn and Dean Zerbe, his counsel since 2009 on this matter. It appears that Birkenfeld’s award...
by Lynam Knott | Sep 10, 2012 | Aggressive Tax Positions, Uncertain Tax Positions
Today we released our 2012 “Ferraro 500” list, which reorders Fortune 500 companies based on the size of their Unrecognized Tax Benefit reserves. This annual study always has some interesting results and outliers. For example, Fortune 500 corporate profits...
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