Archive for June, 2008
Monday, June 30th, 2008
The Internal Revenue Service is taking the unprecedented step of seeking Swiss bank records in search of what it suspects could be up to $20 billion worth of assets hidden by U.S. taxpayers.
Justice Department lawyers said late Monday that they had filed court documents in Miami asking a judge to ...
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Sunday, June 29th, 2008
In the recent case, Schmidt v. IRS, 101 AFTR 2d 2008-XXXX, 05/15/08, Schmidt, a Tax Whistleblower, brought suit in the wrong court, under the wrong legal theory, for which the claim was wrongly processed (i.e. no contract) and for which the United States (IRS) did not waive sovereign immunity.
It is ...
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Wednesday, June 25th, 2008
The legislation, which creates the Tax Whistleblower Reward Program, IRC section 7623 states that the IRS will NOT accept a referral into the Whistleblower Program unless the Whistleblower provides "specific and credible information" regarding the underreporting of tax of at least $2,000,000. No further explanation of what is required to ...
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Thursday, June 5th, 2008
As attractive as the Tax Whistleblower Reward Program appears to reward-seeking informants, many would-be informants are skeptical of the promises made by Congress in IRC section 7623 and by the IRS in various announcements designed to entice participation. However, as a former IRS attorney, I can verify that the promises ...
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Tuesday, June 3rd, 2008
The Tax Court yesterday issued a Press Release and a Notice of Proposed Amendments to its Rules of Practice and Procedure on Tax Whistleblower award actions. These proposed amendments address the recently (December 20, 2006) enacted legislation of IRC Section 7623. Specifically, IRC Section 7623(b)(4), concerning the Appeal of Award Determination, ...
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