by Lynam Knott | Sep 8, 2011 | Guidance
On Friday, September 2, 2011, the IRS announced its 2011-2012 Priority Guidance Plan. The 2011-2012 Priority Guidance Plan lists 317 projects that the IRS intends to work on over the next year, including regulatory guidance for the Whistleblower Program under...
by Lynam Knott | Sep 8, 2011 | Guidance, IRS Whistleblower Office, Judicial Review
Yesterday the United States Tax Court decided Friedland v. Commissioner, T.C. Memo 2011-217 (Sept. 7, 2011) in favor of the Internal Revenue Service. Friedland may sound familiar to some, as his previous case against the IRS did not get very far...
by Lynam Knott | Aug 18, 2011 | Award Determinations, Guidance, IRS Whistleblower Office, Whistleblower Awards
Today The Ferraro Law Firm sent out a letter to IRS Commissioner Douglas Shulman (PDF) disputing an IRS policy that is negatively effecting most tax whistleblowers. In July of 2009 Chief Counsel decided – without telling anyone – that the IRS...
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 Hilary Lefko | May 16, 2011 | Award Determinations, Criminal Fines, Guidance, IRS Whistleblower Office
Last week, Ferraro Law Firm partner, Scott Knott, spoke at the IRS’s public hearing on Proposed Treasury Regulations on the definition of “collected proceeds” in the context of paying whistleblower awards under section 7623. Scott joined other...
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...
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