The IRS just released its annual report on the whistleblower program – showing over $616 million dollars brought into the Treasury thanks to the work of tax whistleblowers speaking out about tax evasion. While the awards to tax whistleblowers is not as high as last year’s record of a collection of over $1.4 billion dollars and $312 million in awards – the awards for FY 2019 are still a solid $120 million (by comparison a marked improvement still over the $33.9 million in FY 2017 awards).
Continue Reading 2019 IRS whistleblowers flag tax fraud, offshore accounts and unreported income

A guest post from Dean Zerbe, senior policy analyst for the National Whistleblower Center and former tax counsel for the Senate Finance Committee.

Many people considering blowing the whistle on tax evasion ask themselves the most basic question: Do I have a case that will interest the Internal Revenue Service (IRS)?
Continue Reading Do I Have A Good Case For The IRS Whistleblower Program?

A guest post from Dean Zerbe, senior policy analyst for the National Whistleblower Center and former tax counsel for the Senate Finance Committee.

Tax whistleblowers had good news the other

Continue Reading New Law Provides Protections For Tax Whistleblowers And Better Communication With IRS

The NWC  releases today an extensive commentary that was written by myself and Steve Kohn (with a huge assist from Felipe Bohnet-Gomez) regarding the Treasury Department’s IRS whistleblower reward regs – specifically on the issue of the Treasury’s narrow interpretation of “collected proceeds.”

“Collected proceeds”  — two little words — the definition of which could make a big difference in the success of the IRS whistleblower program going after tax cheats (especially those with illegal offshore accounts).   The NWC commentary provides chapter and verse to the finding that the Treasury and IRS are ignoring the plain language of the whistleblower award statute (Section 7623 of title 26) as well as the history, structure and context of the legislation in seeking thorough regulations to dramatically cut back when a tax whistleblower can get an award.

What is the issue? –
Continue Reading Tax Whistleblower Regs – NWC Calls For Rewrite on Definition of “Collected Proceeds”

By Dean Zerbe, Advisor to NWC and Attorney at Zerbe, Fingeret, Frank & Jadav.

Dean Zerbe

Tax Court in a recent decision – “Whistleblower 10949-13W v. Commissioner of Internal Revenue” – TC Memo 2014-106 (June 4, 2014) made an important ruling favorable to tax whistleblowers (disclosure:  I am counsel for the whistleblower on this case and also benefitted mightily from the work of my colleague Felipe Bohnet-Gomez).  Key is that the Tax Court rejected the IRS argument which at its core is that a whistleblower can’t get an award if the IRS was already aware of the tax issues of the taxpayer.  The Tax Court made clear that if the IRS uses information (information that is material and not just confirming details) provided by the whistleblower in proceeding against a taxpayer (even where the IRS is already aware of the tax issues of the taxpayer) then the whistleblower is entitled to judicial review of an award (ie the whistleblower is potentially eligible for an award under the IRS whistleblower program – Section 7623(b) of the tax code).  The critical statement from the Tax Court is:
Continue Reading Important Win for Tax Whistleblowers in Tax Court