by Lynam Knott | Dec 10, 2012 | Administration of Whistleblower Claims, Guidance, Judicial Review
The Eleventh Circuit released Ware v. Commissioner, an unpublished opinion, in which the Eleventh Circuit upheld the Tax Court’s dismissal of the pro se taxpayers’ request for redetermination of their tax liability and their whistleblower claim. The...
by Lynam Knott | Sep 18, 2012 | Administration of Whistleblower Claims, Guidance, IRS Whistleblower Office, Judicial Review
As discussed in an earlier blog post, the Tax Court formally adopted amendments to the Tax Court Rules of Practice and Procedure on July 6, 2012. The amendments rules include Rule 345, which provides that a whistleblower may proceed anonymously by redacting the...
by Lynam Knott | Jul 31, 2012 | Administration of Whistleblower Claims, Award Determinations, Guidance, IRS Whistleblower Office, Whistleblower Awards
An interesting letter was released last night from IRS Commissioner Shulman to Senator Grassley. Commissioner Shulman’s letter says more about what is in the pipeline for large whistleblower case award determinations than any statement the IRS has made to...
by Lynam Knott | Jul 18, 2012 | Administration of Whistleblower Claims, Award Determinations, Criminal Fines, Guidance, Voluntary Disclosure Initiative, Whistleblower Awards
Tax Analysts recently released a Chief Counsel Memorandum dated April 23, 2012, stating that the IRS cannot pay a section 7623(b) award on recoveries from the failure to report a foreign bank account commonly referred to as “FBAR” penalties. While we...
by Lynam Knott | Jul 9, 2012 | Guidance, Judicial Review
In line with the Tax Court’s Whistleblower favorable ruling in Whistleblower 14106-10W v. Commissioner, 137 T.C. 183 (2011), the court formally adopted Rule 345 on July 6, 2012. The new rule has two effective parts, the first deals with Whistleblowers...
by Lynam Knott | Jun 22, 2012 | Administration of Whistleblower Claims, Award Determinations, Guidance, IRS Whistleblower Office
Fiscal year 2011 was a big year for the IRS whistleblower program according to the IRS Whistleblower Office’s Fiscal Year 2011 Report to the Congress on the Use of Section 7623. Some of the highlights from the report are: The number of submissions in fiscal year...
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