Advantages of the Right Whistleblower Attorney
The typical whistleblower will generally start at the bottom of the pyramid and, with the assistance of an experienced tax whistleblower attorney, will work his OR her way towards the top.
A good tax whistleblower attorney will go above and beyond the pyramid by providing the IRS with even more assistance (e.g., preparing and submitting an audit plan, legal memoranda, etc.) to assist the IRS in its examination.
Always ask your attorney what more he can/will do to top the pyramid.
An attorney who is experienced in tax matters (e.g., Internal Revenue Code, Treasury Regulations, Revenue Rulings, Revenue Procedures, U.S. Tax Court cases, IRS procedures (Internal Revenue Manual), and litigating cases before the Tax Court (Tax Court Rules)) can provide services that cannot be measured in dollars.
The former IRS attorneys at Tax Whistleblower Law Firm, LLC can begin by guaranteeing confidentiality to you. Not only do we take steps to protect your identity, but we guarantee your confidentiality such that neither we nor the IRS will disclose your identity. If we feel, based upon our experience as former IRS trial attorneys, that your testimony will ultimately be necessary in the tax whistleblower matter, we will tell you up front prior to submitting any information to the IRS. This is important because it allows you the option of not going forward should it be likely that your testimony is necessary. The IRS could issue a subpoena to you requiring your testimony in a Tax Court matter against your wishes, and it is best for you to be aware of this prior to submission of your case to the IRS.
Evaluate Other Risks
An experienced tax whistleblower attorney with the Tax Whistleblower Law Firm, LLC can deal with many issues, including but not limited to the following:
If the tax whistleblower’s involvement in the underpayment of tax by a taxpayer might subject the whistleblower to criminal prosecution.
If the tax whistleblower obtained information and documentation while employed by or working as an independent contractor for the taxpayer, whether the gathering of such information might subject the whistleblower to damages for violating “fiduciary duties”, breach of contract, theft, etc.
If the tax whistleblower is an accountant or lawyer, whether or not such information is subject to “privilege” or confidentiality such that the whistleblower might lose his/her license.
Increase the Chances/Assure Acceptance of the Case
The former IRS attorneys at Tax Whistleblower Law Firm, LLC are in the best position to present your case to the IRS for purposes of acceptance to the Tax Whistleblower Reward Program. In addition to completing Form 211, our attorneys will, as the facts and circumstances dictate, do the following:
Determine the statute of limitations in the matter for the years about which you have information and what years are realistically at issue.
Realistically estimate the unpaid tax based upon information you provide, determine the type and amount of penalty likely to be imposed by the IRS, and calculate the interest on the tax and penalty, in an effort to determine if the case meets the minimum threshold.
Present the facts and issues in a simplified and easily understood manner, supported by documentation or other detailed information that will give credibility to the submission of information.
Increase the Reward
The former IRS attorneys at Tax Whistleblower Law Firm, LLC begin by providing a valuable service in an effort to increase the reward under IRC § 7623 from 15% to the maximum 30% by presenting your information along with the following acts:
Create an “Administrative File” similar to what is normally created by the IRS in an examination
Prepare an "audit plan" for the IRS to follow
Prepare Information Document Requests (IDRs) / Summonses normally issued by the IRS, in order further to develop the case on behalf of the IRS
Prepare the case for litigation before the U.S. Tax Court by identifying witnesses whose testimony may be necessary at trial, obtaining certified documents for the benefit of the IRS in proving its case, and providing the IRS with other relevant documents as though the case were going to be litigated by your whistleblower attorney
Prepare a legal tax opinion in a form to be issued by the Office of Chief Counsel when giving advice to the IRS, stating the facts, issues, legal conclusion, and legal discussions.
If you are in possession of valuable information suitable for the Tax Whistleblower Reward Program, it is important that you find the best representation. If you decide to hire an attorney, you should get an attorney who can best maximize your reward and minimize your exposure. The attorneys at Tax Whistleblower Law Firm, LLC are the best attorneys to assist you in this matter. Upon the initial evaluation of your case, we are willing to fly to meet with you to make sure you are comfortable with us and with the firm. If you are interested, please Contact Us or call us at 1-877-404-1040.
Congress expected that tax whistleblowers would benefit from the assistance of competent counsel in submitting their information about underpayments of tax to the Tax Whistleblower Reward Program. For that reason, Congress made payments of attorney's fees deductible by the whistleblower against the reward received.