Tax Whistleblower Laws and Programs (Portfolio 632)

Description

Bloomberg Tax Portfolio, Tax Whistleblower Laws and Programs, No. 632, provides a comprehensive examination of the laws and regulations that govern the IRS whistleblower program, and the practice that has developed under the program.

The Portfolio reviews both the original IRS whistleblower program and the significant changes to the program after the enactment of the Tax Relief and Health Care Act of 2006. Topics covered include:

• Who can be a whistleblower.
• How to file a whistleblower claim.
• How to protect a whistleblower’s identity.
• The IRS’s interpretation of important statutory terms.
• The IRS’s basis for determining the amount of a whistleblower’s award, and awards to date.

The Portfolio also explains the procedures for appealing an IRS whistleblower determination and challenging the IRS in Tax Court. Discovery in Tax Court, as well as court cases that have impacted the IRS whistleblower program, are addressed as well.This Portfolio may be cited as Kelton, Zoglin, Hasegawa, Arens, and Stabile, 632 T.M., Tax Whistleblower Laws and Programs.

Table of Contents

I. Introduction
II. Section 7623(a) Awards: The Discretionary Awards Program
III. Section 7623(b) Awards: The Mandatory Awards Program Collapse Next Level
IV. Filing a Claim for an Award
V. Management of IRS Whistleblower Program
VI. Data on Tax Whistleblower Submissions and Awards
VII. Appealing an IRS Determination to Tax Court
VIII. Beyond the IRS: New York State’s Tax Whistleblower Program