by Lynam Knott | Jun 13, 2017 | Award Determinations, Guidance, Judicial Review, Whistleblower Awards
The United States Tax Court held in Smith v. Commissioner of Internal Revenue that the threshold limitation found in section 7623(b)(5) have “clear meaning” and were intended to limit the nondiscretionary award regime to larger cases. The Court...
by Lynam Knott | May 25, 2017 | Administration of Whistleblower Claims, Award Determinations, Judicial Review, Whistleblower Awards
Today the Tax Court issued an opinion, Whistleblower 4496-15W v. Commissioner of Internal Revenue, granting the IRS’s motion for summary judgement. In this case, the informant had received a preliminary award determination for an award of $2,954,933. ...
by Lynam Knott | Apr 7, 2017 | Administration of Whistleblower Claims, Guidance
In the tax practitioner version of “Were I King,” nearly every one of us has had that moment where we smack our head at something the IRS does or does not do and think, “the IRS should just ….” It is a form of armchair...
by Lynam Knott | Mar 29, 2017 | Aggressive Tax Positions, Offshore Assets, Taxpayer Underpayment, Uncertain Tax Positions
A recent study by the Institute on Taxation and Economic Policy details how Fortune 500 Companies are holding a record $2.6 trillion offshore, thereby avoiding $767 billion in U.S. taxes. While we believe much of this amount is the result of lawful tax planning...
by Lynam Knott | Mar 27, 2017 | Aggressive Tax Positions, Enforcement, IRS Budget
Tom Herman had an interesting article in today’s Wall Street Journal about the low chance of getting audited by the IRS. It was nice to see Tom back to writing for the Journal, he used to be the WSJ Tax Report columnist and covered IRS whistleblowing. Tom starts...
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