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 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 | Jun 13, 2012 | Administration of Whistleblower Claims, Award Determinations, Guidance, IRS Whistleblower Office, Whistleblower Awards, Withholding on Award Payments
The IRS released welcome guidance relating to whistleblower claims submitted under its long embattled whistleblower program. With all the recent reports showing that the IRS has numerous problems yet to solve to make its whistleblower program as effective as...
by Lynam Knott | Jan 31, 2012 | Guidance, IRS Whistleblower Office, Whistleblower Awards
They say things come in threes, and last week three program manager technical assistance (“PMTA”) memoranda relating to whistleblower cases were released. Two of the three PMTAs relate to power of attorney forms and the third discusses disclosure of...
by Lynam Knott | Jan 30, 2012 | Award Determinations, Criminal Fines, IRS Whistleblower Office, Whistleblower Awards
Congratulations to our associate, Erica Brady, for the publishing of her article, Does Tax Crime Pay (Whistleblowers)?, in the February 2012 edition of TAXES–The Tax Magazine published by CCH. She has previously blogged about criminal fines as tax whistleblower...
by Lynam Knott | Jan 10, 2012 | Aggressive Tax Positions, Taxpayer Underpayment, Whistleblower Awards
The IRS estimates that the gross tax gap for 2006 is $450 billion, or 17 percent of taxes. The gross tax gap is the amount of the true tax liability faced by taxpayers that is not paid on time. After its enforcement efforts, the IRS estimates that the net...
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