Criminal Fines Archives

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

by Lynam Knott | Nov 17, 2017 | Award Determinations, Criminal Fines, Guidance, Whistleblower Awards

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...

DOJ Tax Division is interested in whistleblower information, but risks of disclosure should be discussed with counsel prior to disclosure.

by Lynam Knott | Dec 9, 2016 | Criminal Fines, Department of Justice

Caroline Ciraolo, Principle Deputy Assistant Attorney General, Department of Justice Tax Division, made clear the importance of whistleblower counsel while speaking at the American Bar Association’s National Institute on Criminal Tax Fraud and Institute on Tax...

Tax Court: “The term ‘collected proceeds’ means all proceeds collected by the Government from the taxpayer.”

by Lynam Knott | Aug 3, 2016 | Criminal Fines, Uncategorized, Whistleblower Awards

The Tax Court’s opinion in Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (2016), was a clear and decisive win for whistleblowers. The IRS has long been improperly trying to limit what should be included in “collected proceeds” and...

Tax Court: Providing information to Federal agencies before filing Form 211 does not render the whistleblower ineligible for an award under section 7623(b).

by Lynam Knott | Jun 2, 2015 | Award Determinations, Criminal Fines, Guidance, IRS Whistleblower Office, Judicial Review

The Tax Court released Whistleblower 21276-13W v. Commissioner of Internal Revenue, 144 T.C. No. 15 today. While this decision is positive news for some whistleblowers, it is also a reminder of the importance of following best practices when filing a...

As IRS and the Department of Justice attempt to do more with less, whistleblowers could be the key to continuing to combat tax shelters.

by Lynam Knott | Nov 6, 2013 | Aggressive Tax Positions, Criminal Fines, Department of Justice, Taxpayer Underpayment

Tax shelters are an on-going battle for the IRS and the Department of Justice with large amounts of money at stake for the government, the taxpayer, and possibly for a knowledgeable whistleblower. Tax shelter cases involve schemes that attempt to manipulate...

Just in Time for the New Year…New Proposed Regulations

by Lynam Knott | Dec 18, 2012 | Administration of Whistleblower Claims, Award Determinations, Criminal Fines, Guidance, IRS Whistleblower Office

Proposed Treasury Regulations for the IRS whistleblower program were released on December 14, 2012. These regulations cover many issues and deserve a complete reading; however, below is a short outline of what each section of the proposed regulations covers....

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