IRS Enforcement Actions Still at Record Lows

Scott A. Knott | Monday, September 17, 2018

A report just released by TIGTA (the Treasury Inspector General for Tax Administration) shows that once again IRS audits of taxpayers are in decline.  Enforcement revenues are slightly up this year, but TIGTA says this is due to a small number of large corporate cases. Some highlights of the TIGTA report: “The number of staff... Continue Reading…

Comment on this article

The Ferraro Law Firm Attends the 42nd Annual Federal Bar Association Tax Law Conference

Stephen U. McCloskey, Jr. | Tuesday, March 13, 2018

On March 9th, Tax Partner Scott Knott and I attended the Federal Bar Association Tax Law Conference in Washington, D.C.  Known colloquially as the “inside the beltway tax conference,” many high ranking federal government employees from DOJ, Treasury, and the IRS were in attendance and speaking on various new developments in the tax law. The... Continue Reading…

Comment on this article

Filing Season Fraud and Whistleblowers

Scott A. Knott | Tuesday, March 13, 2018

We get absolutely deluged with hundreds of calls a day during tax return filing season about all kinds of fraud, particularly identity related scams and claiming child exemptions improperly.  In 2016, there was a 400% increase in tax related phishing and malware attacks, and 969,000 potentially fraudulent refunds claiming up to $6.5 billion. You may... Continue Reading…

Comment on this article

Whistleblower Office Annual Report for 2017 Reveals the Program’s Challenges and Opportunities.

Scott A. Knott | Monday, January 08, 2018

Happy New Year! The new year brings a time to reflect back on the past year, on things that went well, things that went not-so-well, and how you would like to do things going forward.  In the spirit of looking back over the last year, the IRS Whistleblower Office released its FY 2017 Annual Report... Continue Reading…

Comment on this article

Rapidly Growing SEC Whistleblower Program Creates Opportunities for Tax Whistleblowers

Stephen U. McCloskey, Jr. | Monday, December 04, 2017

Many tax fraud cases also involve securities law violations.  For instance, corporations engaged in tax evasion may also be creating fraudulent financials or offering securities to investors by providing misleading or untruthful information.  The most common compliant categories reported by whistleblowers to the SEC in fiscal 2017 were Corporate Disclosures and Financials, Offering Fraud, Manipulation,... Continue Reading…

Comment on this article

Senator Grassley’s Amendment to Clarify the Definition of “Collected Proceeds” is Added to the Senate Tax Mark Up

Erica L. Brady | Friday, November 17, 2017

Late on November 16th, the Senate Finance Committee voted to approve its iteration of the Tax Cuts and Jobs Act, passing the measure on a party-line 14-12 vote.  The full version can be found here.  Of particular interest to our readers here is one of the amendments that was added to this in committee.  Senator... Continue Reading…

Comment on this article

Fiscal 2018 Sequestration to Reduce IRS Whistleblower Awards by 6.6 Percent. . . For Now

Stephen U. McCloskey, Jr. | Thursday, October 12, 2017

The IRS announced that whistleblower awards paid under section 7623 on or after October 1, 2017 and on or before September 30, 2018, will continue to be reduced by the “sequestration reduction rate”, which has now been lowered slightly to 6.6 percent.  The 6.6 percent fiscal 2018 sequestration reduction rate represents a .3 percent decrease... Continue Reading…

Comment on this article

Blowing the Whistle on State Sales and Use Tax Violations.

Gregory S. Lynam | Monday, September 11, 2017

There seems to be as many ways to cheat on your taxes as there are taxes.  State sales and use taxes are no different.  Some may not realize it but sales and use taxes are two different taxes.  Sales tax is usually collected by the seller at the time you buy an item and most... Continue Reading…

Comment on this article

Tax Court retains jurisdiction while Whistleblower Office issues revised determination, denies IRS Motion for Remand.

Erica L. Brady | Friday, August 04, 2017

On July 28, 2017, the Tax Court denied the April 14, 2016 Joint Motion to Remand the case to the IRS Whistleblower Office.  In the joint motion, the parties represented that the IRS Whistleblower Office had reconsidered its determination.  The Tax Court previously issued an order for the parties to file a status report by... Continue Reading…

Comment on this article

U.S. Tax Court: The section 7623(b)(5)(B) phrase “amounts in dispute” is not specifically limited to only those amounts directly or indirectly attributable to the whistleblower information.

Erica L. Brady | Tuesday, June 13, 2017

The United States Tax Court held in Smith v. Commissioner of Internal Revenue that the threshold limitation found in section 7623(b)(5) have “clear meaning” and were intended to limit the nondiscretionary award regime to larger cases.  The Court explained: Subsection (b)(5) is intended to make the nondiscretionary award program of subsection (b)(1) and (2) applicable... Continue Reading…

Comment on this article