The Ferraro Law Firm
Washington D.C. — Miami, Florida
Tax Whistleblower award / reward amount determinations are partly within the discretion of the IRS. With that fact in mind, think of the entire process as a tax controversy in reverse and the initial submission of information as your audit findings to the IRS. Your case should be presented to the IRS with the assumption that you will be challenging the amount of your award determination in Tax Court after the IRS collects the tax from the taxpayer.
Having a tax lawyer who has experience handling tax controversies and who is admitted to practice in the U.S. Tax Court greatly increases your chances of getting the money you deserve. To discuss a potential claim, contact our law offices today.
You are not technically required to hire an attorney to make a claim under the new tax whistleblower statute OR to represent yourself in litigation before the United States Tax Court to challenge your tax whistleblower award determination. You CAN do both of those things yourself. You can do your own brain surgery too.
We do not recommend either strategy.
According to the revisions made to Internal Revenue Code Section 7623, IRS whistleblower awards may now total between 15 and 30 percent of the amount collected when the tax whistleblower is determined to have made a substantial contribution. And while the IRS has yet to formally identify those factors that get you a reward of up to 30 percent instead of 15, the difference is likely related to the quality of the information you provide to the IRS and the value you add to their understanding of the issues. Our experienced tax lawyers can help you prepare your submission in a way that the IRS will be able to understand and use.
If you merely make allegations of an underpayment of tax but do not provide actual information that contributes to the IRS’ efforts to pursue the taxpayer—you may still be entitled to an award but it will not total more than 10 percent of the amount collected. Furthermore, the IRS may reduce or even eliminate the reward entirely if it determines the allegations you made did not lead to the collection of the tax. Because of this, you should carefully consider what information you have to present to the IRS and give serious thought to hiring an attorney before any contact with an IRS representative is made.
What are you going to do if the IRS takes your high-quality information and then short changes you?
While the IRS has every incentive to encourage and reward tax whistleblowers, it does not mean you should take an IRS reward determination as the absolute last word on the subject. One of the key revisions made to Section 7623 allows tax whistleblowers to appeal adverse IRS reward determinations in the U.S. Tax Court—a process that The Ferraro Law Firm is well equipped to assist you with.
Confidential Consultations, Nationwide Practice — 1-800-275-3332
If you have information about large-scale tax underpayments but are unsure of its value or what you should do next, be aware that someone else could step forward with similar or even better information and preclude you from getting an award. Let our lawyers review your information to determine the claim's true potential. Contact our Washington D.C. or Miami, Florida, area offices today.
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