Whistleblower Reward Resources
Resources - Legal & Others
See TaxWhistleblowerBlog.Com for commentary on the latest News and Changes in IRS Procedure
Tax programs for which the irs is interested
* Offshore Bank Accounts - The Saga Continues
Tax Whistleblower Law (Internal Revenue Code)
* IRC § 7623 [PDF] Tax Whistleblower Statute
* Tax Relief and Health Care Act of 2006 [PDF] Miscellaneous
* Treas. Reg section 301-6103(n)-2 Disclosure of Return Information in Connection with Written Contracts Among the IRS, Whistleblowers, and Legal Representatives of Whistleblowers (March 15, 2011)
* Proposed Treas. Reg. § 301.7623-1 Rewards and awards for information relating to violations of internal revenue laws (Jan. 14, 2011).
* Treas. Reg. § 301.6103(n)-2T[PDF] Disclosure of return information in connection with written contracts among the IRS whistleblowers and legal representatives of whistleblowers. (Mar. 25, 2008)
Internal Revenue Notices
* IR Notice 2008-4 Claims Submitted to the IRS Whistleblower Office under Section 7623 (Jan. 14, 2008)
* IR-2007-201 - Procedure Unveiled for Reporting Violations of the Tax Law, Making Reward Claims (Dec. 19, 2007)
* IR-2007-25 - IRS Begins Work on Whistleblower Office; Whitlock Named First Director (Feb. 2, 2007)
IRS Delegation Orders
* Delegation Order 25-07 (Rev 1) [PDF] Clarifies that the determination of Rewards under IRC § 7623(a) (i.e. the old "informant program") is now under the Whistleblower Office in Washington, DC. (Effective July 1, 2008)
IRS - Web Pages
* The IRS Web pages can be found at the bottom of the Home Page of this web site ...www.rewardtax.com
IRS - FORMS
* Form 211 (Rev. 12-2007) [PDF] Application for Award for Original Information
* Form 3949-A (Rev. 2-2007) [PDF]Information Referral (Use this Form to Report Tax Fraud)
INTERNAL REVENUE MANUAL (IRM)
* Internal Revenue Manual - 25 2 2 Whistleblower Awards IRS procedures for running Tax Whistleblower Program
Tax Court Rules of Practice and Procedure
* Notice of Proposed Amendments to Rules of Practice and Procedure on Whistleblower Award Actions. Written comments on the proposed amendments are due by July 31, 2008.
* Press Release, June 2, 2008
Tax Court Cases Regarding Whistleblowers
* Friedland v. Commissioner, T.C. Memo 2011-90. (April 25, 2011) Tax court reaffirms that it has jurisdiction to hear case when the IRS rejects a claim. In this case, the Whistleblower filed with the court passed the 30 day period in which to file suit. The IRS had instructed the Whistleblower that if he wished to appeal he should file in the Court of Claims which he did and for which the court did not have jurisdiction. Despite being misinformed on where to file, it did not extend the period in which to file in the U.S. Tax Court. The Tax Court did not have jurisdiction to hear the case due to the late filing by the Whistleblower.
* Colman v. US, Case No. 10-219T (January 28, 2011)
U.S. Court of Federal Claims lacks subject matter jurisdiction.
* Cooper v. Commissioner, 135 T.C. No. 4 (July 8, 2010) Court determined that it had jurisdiction in a situation where the IRS rejected the Claim. The IRS claimed it made no determination and therefore there was nothing to appeal. The Tax Court determined that "no determination" was in fact a determination for purposes of appeal granting the tax court jurisdiction.
The Tax Court affirms under the old tax informant program, now known as cases accepted under IRC 7623(a), the IRS has the sole discretion to determine the amount of the reward.