The IRS tax whistleblower program is now five years old and is becoming more and more complex. Well, that is, it is only complex if the attorney knows what they are doing … as they must thoroughly understand the tax whistleblower statute (I.R.C. 7623), whistleblower regulations/notices, Internal Revenue Manual (IRM) tax disclosure issues, confidentiality agreement, tax court rulings, administrative appeals, judicial appeals, reward computations, and on top of this, they must understand a similar set of laws, regulations, and rulings dealing with the underlying substantive tax issue for which the entire tax whistleblower case is based.
Remember, any attorney can assist a tax whistleblower in the submission of a claim. A divorce attorney or a personal injury attorney can fill out a Form 211, Application For Award For Original Information. The Form 211 is not magical nor is it complicated. Many tax whistleblowers have filed their own 211 in the past. It is only after the tax whistleblower files a Claim for a Tax Award/Reward, and if fortunate enough to have their Claim accepted into the IRS Tax Whistleblower Program, that they begin to face the complexity and unknowns of the Tax Whistleblower Program. It is at this time many tax whistleblowers consider hiring an experienced and knowledgeable tax whistleblower law firm to assist them in such very important matters as -
- Supplementing the Claim with new “material” and “relevant” facts.
- Supplementing the Claim with the Law and legal analysis to better the Claim. (i.e. a positive factor).
- Attending the Taint/Debriefing Conferences with the IRS and preparing the client for nearly every question that will be asked by the IRS in the conference.
- Reviewing the reward computations taking into consideration the “collected proceeds,” “tax transcripts,” “Positive factors,” “Negative factors,” etc.
- Representing the tax whistleblower in the “administrative appeal.”
- Representing the tax whistleblower in the “judicial appeal” before the U.S. Tax Court.
The tax whistleblower attorney/lawyer should have the knowledge and experience in all of the above. The attorney/lawyer/law firm should be successful in the submission of all the Form 211 into the IRS tax whistleblower program on behalf of their clients.
The goal of the Tax Whistleblower Law Firm is to
- have the case accepted into the IRS Tax Whistleblower Program,
- maximize the tax rewards/award,
- minimize the IRS examination time, and
- protect the whistleblower’s identity/confidentiality which should include guaranteeing the confidentiality of the whistleblower.
The Tax Whistleblower Law Firm has all the experience to assist in the above. As former IRS attorneys we understand the underlying substantive tax law as well as the whistleblower law. We have submitted tax whistleblower claims with respect to hundreds of taxpayers for billions of dollars. To date, every claim submitted by our firm has been accepted into the IRS Tax Whistleblower Program. Our criteria in submitting a claim is to submit only those claims that we feel that we could litigate and win on behalf of the IRS, if in fact, we were still IRS attorneys.