by Lynam Knott | Mar 14, 2016 | Administration of Claims, Administration of Whistleblower Claims, Guidance, Offshore Assets, Whistleblower Awards
Today the Tax Court released its opinion in Whistleblower 22716-13W v. Commissioner, holding that FBAR civil penalties are not “additional amounts” within the meaning of section 7623(b)(5)(B), and they are not “assessed, collected, … [or] paid...
by Lynam Knott | Sep 24, 2015 | Guidance, Judicial Review, Whistleblower Awards
The Tax Court’s September 16th opinion echoes what every whistleblower litigating in Tax Court knows; the IRS’s Whistleblower Administrative File is insufficient. The petitioners in this case moved to compel production of documents and responses to...
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...
by Lynam Knott | Mar 27, 2015 | Administration of Whistleblower Claims, Guidance
It is a rare that one can say that something exciting for tax whistleblowers has occurred with the proposed budget. However, today is that day. On March 25th, Senator Wicker submitted amendment S.AMDT.620, which is co-sponsored by Senator Grassley. According to...
by Lynam Knott | Aug 20, 2014 | Administration of Whistleblower Claims, Guidance, IRS Whistleblower Office
The IRS released two documents today on their website, Commissioner Koskinen Statement regarding Whistleblower Program and Deputy Commissioner for Service and Enforcement Memorandum. The Commissioner’s statement reaffirmed his commitment and support...
by Lynam Knott | Aug 8, 2014 | Administration of Whistleblower Claims, Guidance, IRS Whistleblower Office
The IRS has finally released the Final Treasury Regulations that we have all been waiting for. While, there were not as many in the Final Regulations as we would have liked to have seen; the changes that were made were important ones. Some of the pros and cons of...
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