by Lynam Knott | Sep 12, 2016 | Guidance, Uncategorized
Today the IRS Whistleblower Office released a 3-page overview of the tax whistleblower process called Publication 5251 – The Whistleblower Claim Process. The new publication purports to provide clarity on: What qualifies for an award How whistleblowers...
by Lynam Knott | Aug 3, 2016 | Criminal Fines, Uncategorized, Whistleblower Awards
The Tax Court’s opinion in Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (2016), was a clear and decisive win for whistleblowers. The IRS has long been improperly trying to limit what should be included in “collected proceeds” and...
by Lynam Knott | Mar 30, 2016 | Uncertain Tax Positions
We began reordering the Fortune 500 based on uncertain tax positions reported in the most recent 10-K filed before June 15th of that year in 2010, the same year that the IRS announced that it was planning to require that certain business taxpayers to report uncertain...
by Lynam Knott | Mar 14, 2016 | Administration of Claims, Administration of Whistleblower Claims, Guidance, Offshore Assets, Whistleblower Awards
Today the Tax Court released its opinion in Whistleblower 22716-13W v. Commissioner, holding that FBAR civil penalties are not “additional amounts” within the meaning of section 7623(b)(5)(B), and they are not “assessed, collected, … [or] paid...
by Lynam Knott | Feb 23, 2016 | Enforcement, IRS Budget
The 2015 IRS Enforcement and Service Report issued this week reveals that both individual and corporate audit rates are declining, with the respective audit rates at a record low .84% and .60% of returns filed. This not only leaves tax dollars on the table for...
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