IRS Tax Whistleblower Articles
IRS Still Inattentive to Whistleblower Program Deficiencies, TIGTA Says
By Jeremiah Coder, Tax Analysts, Tax Notes Today, May 11, 2012 Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss how the IRS could improve its efficiency in processing whistleblower claims.
Whistleblower Petitions Tax Court to Stop IRS From Obstructing Award
By Jeremiah Coder, Tax Analysts, Tax Notes Today, March 7, 2012
The Ferraro Law Firm Tax Partner, Gregory Lynam, discusses various aspects of Mr. Joseph A. Insinga's petition to the Tax Court, including whether Mr. Insinga's claim is award eligible, if the IRS has made an award determination, and what information about the taxpayer is properly included or redacted from the public filings.
Practitioners Note IRS Reversal On Paying Whistleblower Awards For Avoided Refunds
By Diane Freda, BNA Daily Tax Report, February 23, 2012
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the impact of the final Treasury Regulation defining "collected proceeds" on whistleblower awards.
IRS Ignores Comments in Final Definition of Proceeds for Whistleblower Awards
By Jeremiah Coder, Tax Analysts, Tax Notes Today, February 22, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the impact of the adoption of the final regulations for whistleblower award determinations.
Does Tax Crime Pay (Whistleblowers)?
By Erica L. Brady, TAXES - The Tax Magazine, February 2012
Erica Brady of The Ferraro Law Firm discusses why criminal fines and restitution payments are properly included in "collected proceeds," the amount on which the IRS pays a whistleblower award under section 7623.
Whistleblower Anonymity in Tax Court Pleases Informant Representatives
By Jeremiah Coder, Tax Analysts, Tax Notes Today, December 12, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss the importance of the Tax Court's decision to allow a whistleblower to proceed anonymously after balancing the whistleblower's privacy concerns against the public's right to inspection.
Tax Court Whistleblower Anonymity Ruling Aids Informants, Foreshadows Other Changes
By Diane Freda, BNA Daily Tax Report, December 12, 2011
Erica Brady of The Ferraro Law Firm discusses the Tax Court's decision to allow a whistleblower to proceed anonymously.
GAO Faults IRS Whistleblower Program for Award Delays
By Jeremiah Coder, Tax Analysts, Tax Notes Today, September 12, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the GAO report that highlights ways to improve the IRS Whistleblower program.
IRS Whistleblower Program Faulted
By Laura Saunders, The Wall Street Journal, September 10, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the GAO's recent report to Congress on the IRS Whistleblower Program which suggested improvements in timeliness and communication.
Taxes: How To Turn In Your Neighbor to the IRS
By Laura Saunders, The Wall Street Journal, September 3, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the practical aspects of reporting underpayments to the IRS
Practitioners Complain of Whistleblower Award Delays, Seek Changes to IRM
By Jeremiah Coder, Tax Analysts, Tax Notes Today, August 23, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, criticized the IRS's policy of delaying tax whistleblower awards as it waits for the statute of limitations to expire on refund claims and urged the IRS to update the Internal Revenue Manual to reflect more recent public guidance and allow for awards to paid sooner.
Are Criminal Fines "Collected Proceeds"?
By Erica L. Brady, ABA Section of Taxation NewsQuarterly, Summer 2011
Erica Brady of The Ferraro Law Firm discusses why criminal fines are properly included in "collected proceeds," the amount on which the IRS pays a whistleblower award under section 7623.
IRS Whistleblower Office Reports Increased Claims, Awards Activity in 2010
By Jeremiah Coder, Tax Analysts, Tax Notes Today, July 21, 2011
The IRS reported that collections as a result of their Whistleblower Program doubled to nearly half a billion dollars in fiscal 2010. The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss how despite this increase, the amount of award payments remain irregularly low because of a Chief Counsel decision to delay payments until after the section 6511 refund claim period has run.
IRS Doubles Whistleblower Collections In 2010 While Tipsters Wait for Payouts
By Diane Freda, BNA Daily Tax Report, July 21, 2011
Scott A. Knott, Tax Partner with The Ferraro Law Firm, explains how the IRS's policy to delay award determinations until after the section 6501 and section 6511 period of limitations has run has caused a significant dip in awards paid in FY 2009 and a smaller amount of awards paid relative to amounts collected within FY 2010.
Attorneys Say Recent Ruling Tests Power To Compel Audits of Whistleblower Claims
By Diane Freda, BNA Daily Tax Report, June, 27, 2011
Erica Brady of The Ferraro Law Firm discusses the impact of the Cooper decision and the Tax Court's jurisdiction to review all award determinations.
Tax Court Can't Force IRS to Reconsider Whistleblower Award Denials
By Jeremiah Coder, Tax Analysts, Tax Notes Today, June 21, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the limits of the Tax Court's review an IRS administrative decision not to pursue an audit and why the Tax Court claimed jurisdiction over the case only to dismiss it on a motion for summary judgment.
Practitioners Urge IRS to Attract More Whistleblowers
By: George L. Yaksick, Jr., CCH Federal Tax Day, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, encouraged the IRS to take a more expansive view of collected proceeds in the Final Treasury Regulations than they did in the Proposed Treasury Regulations, pointing out that the language may be too narrow to cover common situations in which refunds are denied in the course of a tax controversy.
Speakers Complain of Narrow Proceeds Definition for Whistleblower Awards
By Jeremiah Coder, Tax Analysts, Tax Notes Today, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, addresses a government panel regarding concerns over the definition of collected proceeds in the Proposed Treasury Regulation, specifically that the language proposed is too narrow to pick up all the situations where an award should be paid to a whistleblower. Additionally, Knott said that waiting to pay awards until the taxpayer's period of limitations for filing a refund has closed is obsolete now that awards can be paid on refund protection claims.
Officials Clarify Net Operating Losses Role In Reward Calculations for Whistleblowers
BNA Daily Tax Report, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, expressed concern that the current guidance ignored credit balances generally and created confusion by including the specific term, "overpayment credit balances."
A New IRS Form Brings New Risks
By Katie Wagner, Agenda, May 2, 2011
Scott A. Knott, Tax Partner with The Ferraro Law Firm, discusses how the new Schedule UTP will change the risk analysis for companies required to report uncertain tax positions to the IRS and how the new reporting requirements could change IRS audits in the future.
IRS Withholding on Whistleblower Awards Ignites Controversy
By Jeremiah Coder, Tax Analysts, Tax Notes Today, April 22, 2011.
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the pitfalls of the IRS's decision to withhold on whistleblower awards absent statutory authority for such withholdings. Knott also discusses the IRS's position to exclude criminal fines from collected proceeds, characterizing PMTA 2010-60 as "a proverbial line in the sand on the issue," and the issue will likely have to be litigated. Lynam also discusses the ability of anonymity procedures to prevent the target taxpayer's information and the whistleblower's information from being disclosed during review by the Tax Court.
IRS Pays First Enhanced Whistleblower Award
By Jeremiah Coder, Tax Analysts, Tax Notes Today, March 15, 2011.
Finally. Scott A. Knott and Gregory S. Lynam, Tax Partners with The Ferraro Law Firm, discuss additional issues that have been raised and what we have learned about how the IRS is handling award payments from the first publicized award payment.
IRS Issues Final Regs On Disclosure Of Return Information To Whistleblowers
By George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, March 17, 2011
Scott Knott, Tax Partner with The Ferraro Law Firm, explains how the finalization of the section 6103(n) regulations will have a minimal impact on whistleblowers because the IRS is not entering into section 6103(n) agreements either out of extreme caution bordering on neglect, a failure of internal communications, or both.
IRS Finalizes Whistleblower Rules Requiring Contract for Disclosure of Return Information
By Diane Freda, BNA Daily Tax Report, March 15, 2011
Erica L. Brady of The Ferraro Law Firm discusses how the IRS is squandering an opportunity by failing to enter into section 6103(n) agreements with whistleblowers.
Treasury Finalizes Whistleblower Contract Regs but Isn't Using Them
By Jeremiah Coder, Tax Analysts, Tax Notes Today, March 15, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss the failure of the IRS to enter into section 6103(n) agreements with whistleblowers, missing an opportunity to fully utilize the whistleblower's inside knowledge and tax expertise.
New Offshore Voluntary Disclosure Initiative Features 25 Percent Penalty, Greater Clarity
By Marie Sapirie, Tax Analysts, Tax Notes Today, February 9, 2011
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses why whistleblowers will remain an integral part of enforcement of tax laws where an individual actively sought to avoid taxes and is hiding money offshore.
Federal Claims Court Chides IRS for Erroneous Whistleblower Appeals Instructions
By Jeremiah Coder, Tax Analysts, Tax Notes Today, February 2, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss a whistleblower's award determination appeal rights under the 2006 amendments to section 7623(b).
Panelists Say IRS Asserting No Appeal When Whistleblower Claim Not Pursued
By Alison Bennett, BNA Daily Tax Report, January 24, 2011
Erica Brady from The Ferraro Law Firm discussed at an American Bar Association Tax Section Conference how whistleblower claims are processed by the IRS.
Proposed Regs Expand Definition Of Proceeds Collected Under IRS Whistleblower Rules
By George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, January 20, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, explains that while the proposed regulations expand the definition of collected proceeds, the proposed regulations are vague and may or may not cover any number of scenarios involving credit carrybacks or carryforwards, and other taxpayer-favorable adjustments.
IRS Proposes Expanded Definition for Whistleblower Awards
By Jeremiah Coder, Tax Analysts, Tax Notes Today, January 18, 2011
The Ferraro Law Firm Tax Partners, Gregory Lynam and Scott Knott, discuss the proposed regulations that expand the definition of collected proceeds, and the need for additional guidance to clarify when an award is available and how it will be determined.
IRS Alters Rules to Pay Informants in More Cases
By Ryan J. Donmoyer, Bloomberg BusinessWeek, January 14, 2011
This article discusses the change in the IRS's reversal of an earlier position through the publication of proposed treasury regulations, making it more likely that an informant will collect a reward when they come forward.
IRS Whistleblower Office Reports High Submissions, Omits Controversial Issues
By Jeremiah Coder. Tax Analysts, Tax Notes Today, December 15, 2010
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss how now, before the IRS begins to pay awards, is the best time to come forward with information because they expect that once the IRS begins to pay awards the IRS Whistleblower Office will be inundated with submission, while now the number of submissions is relatively flat.
Practitioners Disagree Over Effect of UTP Reporting on Whistleblower Claims
By Jeremiah Coder, Tax Analysts, Tax Notes Today, September 2, 2010
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the effect the new UTP reporting rules on future whistleblower claims.
IRS Plan to Uncover Companies' Tax Strategies
By David Kocieniewski, The New York Times, August 24, 2010
Fortune 500 companies' reserves for uncertain tax positions were approximately $200 billion, according to The Ferraro 500, a database ranking the Fortune 500 companies by their tax reserves. The IRS plans to mandate that corporations disclose their uncertain tax positions.
IRS Whistleblower Guidelines Spark Criticism
By Martin Vaughan, Dow Jones Newswires, June 18, 2010
U.S. Senator Charles E. Grassley (R., Iowa) and The Ferraro Law Firm Tax Partner, Gregory S. Lynam, commented on the new IRS whistleblower award procedures.
IRS Rolls Out Long-Awaited Procedures for Making Tax Whistleblower Awards
By Lauren Gardner, BNA, Daily Tax Report, June 18, 2010
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, commented on the award procedures released by the IRS.
IRS Issues Whistleblower Award Determination Procedures
By Jeremiah Coder, Tax Analysts, Tax Notes Today, June 18, 2010
The new IRS whistleblower award procedures were analyzed by The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam.
Americans Seeking Reward Money Inform IRS on Others
By Ryan J. Donmoyer, Bloomberg.com, May 4, 2010
At a conference in Miami, IRS Whistleblower Office Director said that the IRS is close to issuing guidance on how it is going to pay out awards to tax whistleblowers.
IRS Gives Tax Informants More Bites
By Arden Dale, Dow Jones Newswires, February 26, 2010
The Ferraro Law Firm Tax Partner Scott A. Knott and IRS Whistleblower Office Director Stephen Whitlock commented on the recent favorable changes in IRS procedures for handling cases that involve taxpayer insiders as whistleblowers.
The IRS has revised its stance toward whistleblower information submitted by informants who are current employees of the organization. The Ferraro Law Firm Tax Partners Scott A. Knott and Gregory S. Lynam discuss how this change in policy will remove roadblocks and allow the IRS to use all of the information a current employee, who is in rightful possession of such information, is willing to provide.
Tax Informants Are On The Loose
By Janet Novack and William P. Barrett, Forbes.com, November 24, 2009, Forbes Magazine, December 14, 2009
In this article, The Ferraro Law Firm Tax Partner Gregory S. Lynam points out the necessity of tax informants to identify weak links in complex transactions designed to avoid U.S. taxes.
IRS Whistleblower Claims Quadruple on Informants
By Ryan J. Donmoyer, Bloomberg News, October 1, 2009
Submissions to the IRS Whistleblower Office quadrupled between fiscal 2007 and 2008; mentioned is the Washington, D.C. office of The Ferraro Law Firm which was opened to handle these cases.
Tax Whistle-Blowing: Many Cases, Few Results
By Jeremiah Coder, Tax Analysts, October 9, 2009
The Ferraro Law Firm Tax Partners Gregory S. Lynam and Scott A. Knott discuss their experiences representing clients in tax whistleblower cases.
Teed Off Residents Drive Developer to Brink of Ruin
By William M. Buckley, The Wall Street Journal, September 24, 2009
A client of The Ferraro Law Firm, Dr. Michael Lissack, discussed his submission to the IRS Whistleblower Office alleging that a developer underpaid $100 million in taxes by not taking membership deposits into income.
Proposed Regs on Contingent Fees Incorporate Interim Guidance
By Jeremiah Coder, Tax Analysts, July 28, 2009
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, offers insights into why allowing contingency fees for whistleblower cases is consistent with the overall ban of contingency fees for tax-related fees.
International Cases Contribute to Dramatic Increase in Whistle-Blowers, U.S. Reports
By David D. Stewart, Tax Analysts, Tax Notes Today, February 2, 2009
The Ferraro Law Firm Tax Partner Scott A. Knott and IRS Whistleblower Office Director Stephen Whitlock gave a presentation about tax whistleblowers and international tax issues at the Florida Bar Tax Section/FICPA Meeting in Miami.
Experts Predict Tax Court's Amended Rules May Encourage Whistleblower Actions
By George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, October 16, 2008
The Ferraro Law Firm Tax Partners Gregory S. Lynam and Scott A. Knott commented on the new sections of the U.S. Tax Court Rules of Practice and Procedure that relate to whistleblower actions.
Tax Court Amends Whistleblower Rules
By WebCPA staff, WebCPA.com, October 14, 2008
Comments to the Tax Court filed by The Ferraro Law Firm and others led to an acknowledgement by the Court that the identity of a whistleblower appealing their award should be protected.
Tax Collection: Whistleblower Tips Keep Coming; Program Future Unclear; Awards Remain Mystery
By Laura Mahoney, BNA, Daily Tax Report, September 16, 2008
The Ferraro Law Firm Tax Partner Gregory S. Lynam and IRS Whistleblower Office Director Stephen Whitlock provided insights and updates on the IRS Whistleblower Program at the American Bar Association Section of Taxation meeting in San Francisco.
IRS Whistle-Blower Office Sees Huge Jump in Claims, Official Says
By Jeremiah Coder, Tax Analysts, Tax Notes Today, September 16, 2008
The Ferraro Law Firm Tax Partner Gregory S. Lynam and IRS Whistleblower Office Director Stephen Whitlock were quoted as panelists of a discussion about tax whistleblowers at the American Bar Association Tax Section Meeting in San Francisco.
Practitioners Want More IRS Interaction With Whistle-Blowers Making Claims
By Jeremiah Coder, Tax Analysts, Tax Notes Today, August 15, 2008
The Ferraro Law Firm Tax Partners Scott A. Knott and Gregory S. Lynam commented on the state of the IRS procedures for handling whistleblower claims in large corporate cases.
Why the Work of In-House Accountants is NEVER Subject to the Tax-Practitioner Privilege of Section 7525
By Gregory S. Lynam, Tax-Whistleblower.com, June 30, 2008
Can you turn over to the IRS documents prepared by accountants directly employed by the taxpayer? This article addresses why the tax-practitioner privilege of section 7525 does not apply to the work of in-house accountants.
Law Firm Submits New Record Whistle-Blower Claim
By Jeremiah Coder, Tax Analysts, Tax Notes Today, June 16, 2008
The Ferraro Law Firm in a June 13 press release announced it was submitting a $4.4 billion tax whistle-blower claim against a Fortune 500 company.
Tax Whistleblower Action Claims $4.4 Billion Tax Underpayment by Fortune 500 Company
By The Ferraro Law Firm, BNA, June 13th, 2008
A submission to the Internal Revenue Service Whistleblower Office alleges that a Fortune 500 company has underpaid its U.S. tax liability by more than $4.4 billion--over a short period of time--by engaging in abusive tax transactions, an attorney representing the whistleblower announced June 13.
Law Firm Files First $4 Billion Tax Whistleblower Submission with IRS
By Paul Caron, TaxProf Blog, June 13, 2008
The Tax Prof blogs a record $4.4 billion tax whistleblower submission regarding a Fortune 500 company.
Friday the 13th Poses $4.4 Billion of Bad Luck for Fortune 500 Company
By The Ferraro Law Firm, PR Newswire, June 13, 2008
The Ferraro Law Firm filed a new record tax whistleblower submission of more than $4.4 billion to the IRS Whistleblower Office.
Tax Court Proposes New Rules For Electronic Service, Whistleblower Claims
By George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, June 12, 2008
The U.S. Tax Court recently proposed amendments to its Rules of Practice and Procedure to encompass electronic service of filings.
Tax Court Proposes New Rules for Electronic Service, Whistleblower Claims
By George L. Yaksick Jr., CCH Newsletter, Federal Tax Weekly, June 12, 2008
New Tax Court rules set forth procedures for appealing whistleblower award determinations.
Whistle Blower Regs Allow Limited Return Information Disclosure
By Jeremiah Coder, Tax Analysts, Tax Notes Today, March 26, 2008
The IRS issued temporary and proposed regulations on March 24 that will allow some measure of tax return information disclosure to whistleblowers.
IRS May Pay 30% of Tax Recoveries to Liechtenstein Informant
By Ryan J. Donmoyer, Bloomberg.com, February 29, 2008
The Ferraro Law Firm Partner Scott A. Knott was interviewed for this piece.
DC Law Firm Spearheads $4 Billion In Whistleblower Tax Claims
By Glen Shapiro, LawAndTax-News.com, January 16, 2008
The Ferraro Law Firm files a tax whistleblower submission of more than $600 million about a household-name company.
IRS Whistleblower Office Receives $4 Billion in Submissions from One Law Firm
By The Ferraro Law Firm, PR Newswire, January 11, 2008
The Ferraro Law Firm filed a tax whistleblower submission of more than $600 million to the recently created IRS Whistleblower Office.
WSJ on Tax Whistleblower Lawyers
By Paul Caron, TaxProf Blog, December 27, 2007. The Tax Prof blogs Wall Street Journal article regarding Scott A. Knott and Gregory S. Lynam, Tax Partners of The Ferraro Law Firm.
Tipster Rewards Require Patience
By Tom Herman, The Wall Street Journal, December 26, 2007. Blowing the whistle on big-time tax cheats could make some informants wealthy -- as long as they have hard evidence and plenty of patience.
Law Firm Files First $2 Billion Tax Whistleblower Submission with IRS
By Paul Caron, TaxProf Blog, December 12, 2007. The Tax Prof blogs a record $2 billion tax whistleblower submission regarding one of the world's largest companies.
Record $2 Billion Tax Whistleblower Submission Filed
By The Ferraro Law Firm, PR Newswire, December 11, 2007. The Ferraro Law Firm submitted a tax whistleblower submission of more than $2 billion to the recently created IRS Whistleblower Office.
Accounting Ethics Rules Give In-House CPAs the Green-Light to Blow the Whistle
By Scott A. Knott and Gregory S. Lynam, Tax-Whistleblower.com, October 23, 2007. Professional advisors representing companies or wealthy individuals who have discovered information about large tax underpayments have a strong financial incentive to use the high quality information obtained while servicing the taxpayer in a submission to the IRS Whistleblower Office.
IRS Can Pay Large Awards to Nearly Anyone for Information About Tax Underpayments
By Scott A. Knott and Gregory S. Lynam, Tax-Whistleblower.com, October 23, 2007. Amended 26 USCA 7623 of the Internal Revenue Code now provides that persons who have information about underpayments of tax or violations of the Code who provide that information to the IRS can receive substantial cash awards.
Ernst & Young Embroiled in Whistleblower Case
By WebCPA staff, WebCPA.com, October 15, 2007
Tax whistleblower submission comes after four partners at Ernst & Young were indicted in May 2007 for conspiring to sell fraudulent tax shelters.
Tax Whistleblower Action Claims $1 Billion Underpayment by Fortune 500 Company
By J.P. Finet, BNA, Daily Tax Report, October 12, 2007
A submission to the Internal Revenue Service Whistleblower's Office alleges that a Fortune 500 company represented by Ernst & Young LLP entered into a series of transactions to improperly reduce its taxes by more than $1 billion, two attorneys representing the whistleblower told BNA Oct. 11.
Tax Whistleblower May Get $300 Million Award
By Aly Adair, AssociatedContent.com, October 11, 2007
By law, the minimum award the IRS must pay to a tax whistleblower that makes a substantial contribution to the success of the tax collection is 15% of the amount collected.
Law Firm Files First $1 Billion Tax Whistleblower Submission with IRS
By Paul Caron, TaxProf Blog, October 10, 2007
The Tax Prof blogs a record $1 billion tax whistleblower submission regarding a Fortune 500 company.
