An informative Blog written by Thomas Pliske and Shine Lin of the Tax Whistleblower Law Firm regarding important issues dealing with the IRS Whistleblower Informant Program.
I.R.C. § 7623(b)(4) provides in pertinent part, “Any determination regarding an award under paragraph (1), (2), or (3) may, within 30 days of such determination, be appealed to the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter).”
Read MoreThe Court appears to reach the conclusion that the Court will just keep sending the case back to the IRS for reconsideration via a Remand when the IRS fails to adequately support its findings, or ultimately abuses its discretion. The key question here is: how many times will Congress, and the Court allow the IRS to keep getting the determination wrong? At some point, reason suggests that the Court will have to make a real determination on whether the IRS erred in their determination and order an appropriate remedy to redress the wrong, or the Court’s review under I.R.C. § 7623(b)(4) will be meaningless.
Read MoreCan a whistleblower get a second opportunity to appeal the IRS’ determination of award in whistleblower claims?
Read MoreThe Tax Whistleblower Law Firm (TWLF) specializes in the preparation of the Form 211 Claims package to report underpaid taxes to the Internal Revenue Service (IRS) under the Tax Whistleblower Reward Program. The TWLF team, anchored by a former IRS attorney, consists of qualified tax attorneys with over 40 combined years of tax-related legal experience. Our services are solely dedicated in the IRS Whistleblower Program and U.S. Tax Court litigation of Tax Whistleblower determinations.
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