by Lynam Knott | Jul 21, 2011 | Award Determinations, Guidance, IRS Whistleblower Office
The IRS has released on its website the “Fiscal Year 2010 Report to the Congress on the Use of Section 7623,” which details the progress of the IRS Whistleblower Office over the Fiscal 2010 year (thru September 30, 2010). The first and most important...
by Lynam Knott | Jun 21, 2011 | Award Determinations, IRS Whistleblower Office, Judicial Review
The US Tax Court just released its summary judgment decision in William Prentice Cooper, III v. Commissioner, 136 T.C. No. 30 (June 20, 2011). In the first true exercise of its new jurisdiction over tax whistleblower cases, the Tax Court showed that it will...
by Lynam Knott | Jun 2, 2011 | IRS Whistleblower Office, Uncertain Tax Positions
On June 1, 2011, Citizens for Tax justice issued a preliminary report [PDF] showing that 12 major United States corporations had a cumulative effective tax rate of -1.5% on $171 billion in United States profits. The preliminary report is a preview of a larger...
by Lynam Knott | Apr 21, 2011 | Award Determinations, Criminal Fines, Guidance
PMTA 2010-60, Criminal Fines and Whistleblower Awards [PDF], is a line in the sand signaling that the IRS is willing to litigate whether criminal fines are properly included in “collected proceeds.” The Proposed Treasury Regulations [PDF] are...
by Lynam Knott | Apr 21, 2011 | Award Determinations, Guidance, Withholding on Award Payments
We informed the Whistleblower Office three years ago that we did not believe that the IRS was either required to or had the legal authority to withhold on award payments to whistleblowers under section 7623. With the payment earlier this month of the first...
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