Are Criminal Fines “Collected Proceeds” under section 7623?

Congratulations to our associate, Erica Brady, for the publishing of her article, Are Criminal Fines “Collected Proceeds”?, in the Summer 2011 edition of the ABA Section of Taxation NewsQuarterly. She has previously blogged about criminal fines as tax whistleblower proceeds, and we think that the discussion of this contentious issue has just begun.