In an effort to promote the IRS Whistleblower program, the Tax Whistleblower Law Firm is willing review and suggest changes and modifications to IRS Whistleblower Claims at no charge to those individuals that desire to file their own IRS Whistleblower Claims. We are willing to do this at no cost to the Whistleblower because we believe in the IRS Whistleblower program and want to see it successful in the years ahead. We, as taxpayers, are all in this together, and certain taxpayers should not be circumventing the law simply because they can, or have been in the past. The only condition is that we have the opportunity to provide our review prior to submission of the IRS Whistleblower Claim to the IRS.
This blog will provide information to those individuals that would like to file an IRS Whistleblower claim without the assistance of an IRS Whistleblower attorney/lawyer.
Although it does not appear to be a complex matter, the IRS simply requires that such an individual file a one page Form 211, Application for Award for Original Claim….nothing more. There are 18 relatively easy questions, which include 9 questions (name address, etc.) just about the whistleblower.
As the IRS states in the instructions to the filing of the IRS whistleblower claim, as well in Notice 2008-04, the information provided should be “specific and credible.” To the extent the IRS whistleblower has documentation, we certainly recommend that the IRS whistleblower claim contain not only specific and credible information, but be accompanied by supporting (i.e. relevant) documentation. Remember, with specificity comes credibility. All the information should be presented clearly and concisely. Take into consideration all the positive factors the IRS will consider when determining the maximum IRS tax reward that you may be entitled and try to meet those positive factors. See our prior blog on the IRS computation of a tax reward
Our office also recommends that the 211 claim, or 211 claim package, contain the same type of information that an IRS administrative file might contain, should the IRS have completed its examination and sent the case forward for trial. As former IRS attorneys we strive to provide all the necessary information and documentation that the IRS needs in the processing of the claim and the completion of the examination, including a legal analysis of the substantive tax issue. We will make specific suggestions as we review the files on a case by case basis for those whistleblowers filing their own claim.
The above is what is recommended for the submission of an IRS whistleblower claim. An experienced and knowledgeable tax whistleblower attorney will only be able to assist if they are tax attorneys familiar with the substantive tax issue and experienced with the IRS whistleblower procedures. Such an attorney will provide value assuring that the 211 Claim is clear and concise and will be accepted into the program. In addition, the IRS whistleblower attorney work to maximize the reward, shorten the examination time (hence the time for pay off or the reward), and protect the identity of the whistleblower, including providing a guarantee.
Other reasons to consider an experienced tax whistleblower attorney include the continuance guidance through what is likely a 5 to 7 year process. The attorney will supplement the claim over time with new and material information should such information exist. The attorney will accompany the whistleblower to any meetings for which the IRS desires to meet with the whistleblower and will prepare the whistleblower for such meeting. Lastly, the experienced tax whistleblower attorney will handle the administrative and judicial appeal at no additional cost.
The Tax Whistleblower Law Firm has submitted hundreds of tax whistleblower claims over the years for billions of dollars and, to date, has had every case accepted into the IRS Whistleblower Program. Therefore, again, if you are filing an IRS whistleblower claim and would like, at no charge or commitment, comments and recommendation by the former IRS attorneys of the Tax Whistleblower Law Firm with respect to your IRS whistleblower claim, call 1-877-404-1040 or complete an email request on our Contact page.