by Lynam Knott | Mar 7, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review, Taxpayer Underpayment
Joseph A. Insinga, retired Rabobank Finance Specialist, filed a petition with the Tax Court arguing that the IRS’s continued refusal to issue a formal determination constitutes a de facto rejection of his claim and appeals this de facto rejection. ...
by Lynam Knott | Feb 21, 2012 | Award Determinations, Guidance, IRS Whistleblower Office
Today the Treasury Department issued the finalized Treas. Reg. Section 301.7623-1(a) and (g) relating to the definition of “collected proceeds” for purposes of section 7623 tax whistleblower awards. Although the language of the final whistleblower...
by Lynam Knott | Feb 21, 2012 | Contributor Updates
Kudos to Erica Brady in our Washington DC office for being named by the American Bar Association as a 2012 Nolan Fellow. This award by the ABA’s tax section is given to the top 6 young tax attorneys nationwide who demonstrate excellence and leadership....
by Lynam Knott | Feb 7, 2012 | Department of Justice, Offshore Assets, Voluntary Disclosure Initiative
The latest round of the U.S. crackdown of tax evasion through the utilization of undeclared offshore bank accounts has the US significantly upping the stakes of the game. The U.S. Department of Justice has indicted Wegelin & Co, founded in 1741 – which...
by Lynam Knott | Jan 31, 2012 | Guidance, IRS Whistleblower Office, Whistleblower Awards
They say things come in threes, and last week three program manager technical assistance (“PMTA”) memoranda relating to whistleblower cases were released. Two of the three PMTAs relate to power of attorney forms and the third discusses disclosure of...
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