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 | Jul 3, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review, Whistleblower Awards
Some of our clients and readers of this blog have asked that we publish the amicus curiae brief that The Ferraro Law Firm recently filed with the United States Tax Court in the case of Joseph A. Insinga v. Commissioner of Internal Revenue. Mr. Insinga is...
by Lynam Knott | Mar 7, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review, Taxpayer Underpayment
Joseph A. Insinga, retired Rabobank Finance Specialist, filed a petition with the Tax Court arguing that the IRS’s continued refusal to issue a formal determination constitutes a de facto rejection of his claim and appeals this de facto rejection. ...
by Lynam Knott | Dec 12, 2011 | Award Determinations, Guidance, Judicial Review
The decision of the Tax Court in Whistleblower 14106-10W v. Commissioner should encourage tax whistleblowers that their identity will be protected if they choose to avail themselves of their judicial appeal rights under section 7623(b)(4). The Tax...
by Lynam Knott | Sep 23, 2011 | Award Determinations, Guidance, Judicial Review
I wanted to highlight an article published in the September 19, 2011, issue of Tax Notes, “Scratching Our Heads Over Cooper v. Commissioner” by Michelle M. Kwon. In this article, Ms. Kwon gives a thoughtful discussion of the Tax Court’s...
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...
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