by Lynam Knott | Aug 4, 2017 | Administration of Whistleblower Claims, Award Determinations, IRS Whistleblower Office, Judicial Review
On July 28, 2017, the Tax Court denied the April 14, 2016 Joint Motion to Remand the case to the IRS Whistleblower Office. In the joint motion, the parties represented that the IRS Whistleblower Office had reconsidered its determination. The Tax 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 | Feb 14, 2017 | Administration of Claims, Administration of Whistleblower Claims, Whistleblower Awards
In our experience the IRS is a peculiarly apolitical organization – despite the Lerner email scandal and the targeting of conservative groups for noncompliant tax exempt status claims, almost every position in the IRS is not motivated by or responsive to political...
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 | Mar 27, 2015 | Administration of Whistleblower Claims, Guidance
It is a rare that one can say that something exciting for tax whistleblowers has occurred with the proposed budget. However, today is that day. On March 25th, Senator Wicker submitted amendment S.AMDT.620, which is co-sponsored by Senator Grassley. According to...
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