TAX PROCEDURE (DN 893) ASSIGNMENT REWARDS PAID (OR NOT PAID) BY THE FEDERAL GOVERNMENT TO WHISTLEBLOWERS (DRAFT DATE - OCTOBER 15, 2014)
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1 TAX PROCEDURE (DN 893) ASSIGNMENT REWARDS PAID (OR NOT PAID) BY THE FEDERAL GOVERNMENT TO WHISTLEBLOWERS (DRAFT DATE - OCTOBER 15, 2014) Table Of Contents Table Of Contents Assignment Rewards Paid (Or Not Paid) By The Federal Government To Whistleblowers Examine the following nine provisions of the Constitution Of The United States Of America Examine the following IRC sections Judicial proceedings Discovery of liability and enforcement of Title Examine the following other federal statutes Examine the following facts, issues, opinions, and decisions Granted Denied Court found for IRS because it correctly applied refunds to liabilities Dismissed for lack of jurisdiction, failed to meet threshold requirements Dismissed for lack of jurisdiction, 7623 is not money-mandating Dismissed for lack of jurisdiction, other Petition not timely filed No decision on the merits, withdrawal of petition No decision on the merits, orders by the Court Granted leave for National Whistleblowers Center to file amicus brief Court order for IRS to produce documents Examine the following IRS IR Manual sections Organization and Staffing Information and Whistleblower Awards Examine the following documents issued by: Treasury Department (TD); Internal Revenue Service (IRS); Department Of Justice (DOJ); Treasury Inspector General For Tax Administration (TIGTA); Taxpayer Advocate Service (TAS), and certain other issuers TD News Releases (TDNR) IRS and Taxpayer Advocate Service (TAS) s Publications IRS Revenue Rulings (IRS Rev. Rul.) IRS Revenue Procedures (IRS Rev. Proc.) IRS Legal Memoranda (IRS ILM) IRS Technical Advice Memoranda (IRS TAM) IRS Private Letter Rulings (IRS PLR) IRS Policy Statement (IRS P) IRS Chief Counsel (CC) IRS CC Advice Memoranda (IRS CCAM) IRS Chief Counsel Advice (IRS ECC) IRS Field Service Advices (IRS FSA) IRS Field Attorney Advice (IRS FAA) IRS Determination Letters (IRS DL) IRS Notices IRS Fact Sheets (IRS FS) IRS Announcements (IRS Ann) IRS Information Releases (IRS IR) IRS News Releases (IRS NR) IRS Small Business / Self-Employed (IRS SB/SE) Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
2 IRS Frequently Asked Questions (IRS FAQ) IRS Program Manager Technical Assistance (IRS PMTA) Other documents Examine the following National Whistleblower Center s Releases Examine the following IRS and TIGTA forms and the instructions thereto Examine the following articles, letters, reports, etc. from professional individuals or organizations Examine the following documents by Professor Jegen Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
3 Assignment Rewards Paid (Or Not Paid) By The Federal Government To Whistleblowers Examine the following nine provisions of the Constitution Of The United States Of America - Article 3, Section 2 - Trial by Jury, Original Jurisdiction, Jury Trials. Amendment 1 - The rights of freedom of religion, speech, press, and expression. Amendment 2 - The right of individuals to possess weapons. Amendment 4 - The freedom from search and from seizure of property without a warrant or having probable cause. Amendment 5 - Forbids trial for major crime without indictment by grand jury and no punishment without due process and individuals may not be compelled to testify against themselves and it prohibits double jeopardy. Amendment 6 - In criminal cases, the right to a speedy public trial and the right to legal counsel and the right to confront witnesses during trial. Amendment 7 - Trial by jury in civil cases. Amendment 11 - Some judicial limits. Amendment 14 - Rights of citizens. Amendment 16 - The Congress shall have power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration. Examine the following IRC sections - Judicial proceedings Jurisdiction of District Courts. Discovery of liability and enforcement of Title Expenses of detection of underpayments and fraud, etc. Foreign entity problems Foreign financial institution withholding Foreign entity withholding. Examine the following other federal statutes - Examine the following facts, issues, opinions, and decisions - Granted - Denied - No case is cited under this category. Court found for IRS because it correctly applied refunds to liabilities - Booker T. Morris III v. Commissioner, 104 T.C.M. (CCH) 124 (Tax Ct. 07/30/2012); 2012 Tax Ct. Memo LEXIS Hearing before levy. Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
4 Authority to make credits or refunds Failure to pay over tax. Dismissed for lack of jurisdiction, failed to meet threshold requirements - Anonymous 1 et al. v. Commissioner, 2013 TNT (05/10/2013) Expenses of detection of underpayments and fraud, etc. Vacated order on 11/02/2012. Investigation still ongoing so no tax proceeds collected. Cooper v. Commissioner, 136 T.C. 597 (Tax Ct. 06/20/2011); 2011 U.S. Tax Ct. LEXIS Determination by Tax Court Canvas of districts for taxable persons and objects Examination of books and witnesses Expenses of detection of underpayments and fraud, etc. Dismissed for lack of jurisdiction, 7623 is not money-mandating - Amsinger v. United States, 99 Fed. Cl. 254 (Fed. Cl. 07/07/2011); 2011 U.S. Claims LEXIS Expenses of detection of underpayments and fraud, etc. No contract rights under 7623(a), discretionary statute. Tax Court has exclusive jurisdiction of 7623(b). Tort and Implied-in-law claims dismissed without prejudice. Implied-in-fact claims dismissed with prejudice. Friedland v. United States, No T, 2010 U.S. Claims LEXIS 1042 (Fed. Cl. 05/26 /2010) Gain or loss recognized on property distributed in complete liquidation Abatements Expenses of detection of underpayments and fraud. No contract right under 7623(a), discretionary statute. Tax Court has exclusive jurisdiction under 7623(b). Wilson v. United States, No T, 2007 U.S. Claims LEXIS 268 (Fed. Cl. 07/13/2007) Expenses of detection of underpayments and fraud. No contract right under 7623(a), discretionary statute. IRS Publication 733 does not mandate payment. Dismissed without prejudice. Wolf v. Commissioner, 93 T.C.M (CCH) 1273 (Tax Ct. 05/30/2007); 2007 Tax Ct. Memo LEXIS Notice and opportunity for hearing before levy Expenses of detection of underpayments and fraud. Court has no authority to review discretionary decision to not give awards on information provided prior to Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
5 Dismissed for lack of jurisdiction, other - Dacosta v. United States, 414 F.App x 301 (Fed. Cir. 02/09/2011); 2011 U.S. App. LEXIS Expenses of detection of underpayments and fraud, etc. Failed to allege implied-in-fact contract under 7623(a) in prior suit, so alleged implied-in-fact contract barred in this suit by issue preclusion. Schmidt v. I.R.S., No , 2008 WL (E.D. Mich. 05/15/2008); 2008 U.S. Dist. LEXIS Petition not timely filed Expenses of detection of underpayments and fraud. Petitioner sought damages under Americans with Disabilities Act in lieu of filing suit under 7623 of IRC to avoid 7623's discretionary nature. District Court does not have jurisdiction on claims over $10,000. Friedman v. Commissioner, 102 T.C.M. (CCH) 247 (Tax Ct. 09/07/2011); 2011 Tax Ct. Memo LEXIS Expenses of detection of underpayments and fraud, etc. No decision on the merits, withdrawal of petition - Insinga v. Commissioner, 2013 TNT (04/23/2013) Expenses of detection of underpayments and fraud, etc. Dismissed without prejudice when petition was withdrawn. No decision on the merits, orders by the Court - Insinga v. Commissioner, 2013 TNT (3/21/2013) Expenses of detection of underpayments and fraud. Ordered IRS to respond to petitioner's application to take deposition. Insinga v. Commissioner, 2013 TNT (3/13/2013) Expenses of detection of underpayments and fraud Ordered evidentiary hearing on whether IRS made de facto determination on petitioner's claim for reward. Wong v. CKX, Inc, 890 F.Supp.2d 411 (S.D. NY 9/11/2012); 2012 U.S. Dist. LEXIS No IRC section cited, claim filed under Sarbanes-Oxley Act. Petitioner is entitled to de novo review by district court. Motion to dismiss and motion to compel arbitration both denied. Granted leave for National Whistleblowers Center to file amicus brief - Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
6 Insinga v. Commissioner, 2012 TNT (7/31/2012) Expenses of detection of underpayments and fraud. Court order for IRS to produce documents - Hill v. Commissioner, 2013 TNT (07/24/2013). Examine the following Federal Regulation provisions - (See Expenses of detection of underpayments and fraud. Code of Federal Regulations, Title 26--Internal Revenue, Chapter 1--Internal Revenue Service, Department of the Treasury, Subchapter A--Internal Revenue Practice, Part 301--Procedure and Administration: TD 9519, RIN 1545-BF33--Final Regulations Concerning Taxpayer Assistance Orders. Code of Federal Regulations, Title 31--Money and Finance: Treasury, Subtitle A--Office of the Secretary of the Treasury, Part 10--Practice Before the Internal Revenue Service; Circular 230--Rules Governing Practice Before the IRS. Code of Federal Regulations, Title 26--Internal Revenue, Chapter 1--Internal Revenue Service, Department of the Treasury, Subchapter A--Income Tax, Part 301--Procedure and Administration: Rewards for Information Relating to Violations of Internal Revenue Laws. Code of Federal Regulations, Title 26--Internal Revenue, Chapter 1--Internal Revenue Service, Department of the Treasury, Subchapter A--Income Taxes, Part 301--Procedure and Administration and 602--OMB Control Numbers Under the Paperwork Reduction Act: TD 8780, RIN 1545-AU85--Final Regulations on Information Rewards. Code of Federal Regulations, Title 26--Internal Revenue, Chapter 1--Internal Revenue Service, Department of the Treasury Subchapter A--Internal Revenue Practice, Part 1--Income Taxes: REG , RIN 1545-AM12--Withdrawal of Notice of Proposed Rulemaking, Notice of Proposed Rulemaking and Notice of Public Hearing Income and Currency Gain or Loss with Respect to a Section 987 QBU. Examine the following IRS IR Manual sections - (See Organization and Staffing - IRM Whistleblower Office. Information and Whistleblower Awards - IRM Receiving Information. IRM Whistleblower Awards. IRM Reimbursements to State/Local Law Enforcement Agencies. Examine the following documents issued by: Treasury Department (TD); Internal Revenue Service (IRS); Department Of Justice (DOJ); Treasury Inspector General For Tax Administration (TIGTA); Taxpayer Advocate Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
7 Service (TAS), and certain other issuers - (See gov and TD News Releases (TDNR) - IRS and Taxpayer Advocate Service (TAS) s Publications - Publication Rewards For Information Provided By Individuals To The Internal Revenue Service. Publication Taxpayer Advocate Services of the IRS - How to Get Help with Unresolved Tax Problems. Taxpayer Advocate Service s unnumbered publication - Troublesome Tax Issues? Can t See the Forest for the Trees? Publication 1 - Your Rights as a Taxpayer (with references by Professor Jegen). Publication 17 - Your Federal Income Tax (For Individuals). Publication Divorced or Separated Individuals. Publication Innocent Spouse Relief. Publication Innocent Spouse Relief (Brochure). Publication Why do I have to Pay Taxes? Publication IRS Guide to Free Tax Services. Publication 2053-A - Quick and Easy Access to IRS Tax Help and Tax Products. Publication The IRS Will Figure Your Tax. Publication How do I Adjust My Tax Withholding? Publication Tax Withholding and Estimated Tax. Publication Electronic Return File Specifications for Individual Income Tax Returns. Publication Handbook for Authorized IRS e-file Providers of Individual Income Tax Returns. Publication Help Us Prepare an Accurate Return for You. Publication National Taxpayer Advocate's Annual Report to Congress. Publication National Taxpayer Advocate - FY Objectives. Publication 4445-G - How to Select a Tax Preparer: Tips From The IRS. Publication Internal Revenue Service Return Preparer Review. Publication Recordkeeping for Individuals. Publication Important Tax Records. Publication Tax Withholding and Estimated Tax. Publication Electronic Choices to Pay All Your Federal Taxes. Publication Do You Owe Federal Taxes?. Publication Payment Options. Publication IRS e-file Electronic Payment Options. Publication Can't Pay the Tax You Owe Fact Sheet. Publication Information About Your Notice, Penalty and Interest. Publication Tax Item. Penalties. Publication Practice Before the IRS and Power of Attorney. Publication Limited Practice Without Enrollment. Publication The Examination Process. Publication 3498-A - The Examination Process (Examination by Mail). Publication Achieving Quality Examinations Through Effective Planning, Execution, and Resolution. Publication Examination of Returns, Appeal Rights, and Claims for Refund. Publication What you Should Know About the Audit Reconsideration Process. Publication Overview of Appeals Process Brochure. Publication 5 - Appeal Rights and Preparation of Protests for Unagreed Cases. Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
8 Publication Application, Approval, and Appeal Procedures. Publication Appeals - Introduction to Alternative Dispute Resolution (Fast Track Mediation, Fast Track Settlement, Mediation, Early Referral, And Arbitration). Publication Fast Track Mediation. Publication Extending the Tax Assessment Period. Publication 15 - Employer s Tax Guide. Publication 15-A - Employer s Supplemental Tax Guide. Publication 51 - Agricultural Employer s Tax Guide. Publication Household Employer s Tax Guide. Publication Independent Contractor or Employee. Publication Independent Contractor or Employee? Section 530 Employment Tax Relief Requirements. Publication Questions and Answers About Tax Court Proceedings for Determination of Employment Status Under I.R.C Publication Disclosure & Privacy Law Reference Guide. Publication Disclosure of Information to Federal State, and Local Agencies. Publication Report Cash Payments of Over $10,000 (Received in a Trade or Business). Publication Criminal Investigation - Legal Source Tax Crimes Program Strategy. Publication Penalty Refund Offer. Publication Tax Sheltered Annuity Plans (403 (b) Plans). Publication Investment Income and Expenses (Including Capital Gains and Losses). [Chapter 2 is the relevant Chapter within this Publication. It is titled Tax Shelter and Other Reportable Transactions.] Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. Publication Withholding of Tax on Nonresident Aliens and Foreign Entities. Publication U.S. Tax Guide for Aliens. Publication Tax Highlights for U.S. Citizens and Residents Going Abroad. Publication U.S. Tax Treaties. Publication The IRS Collection Process. Notice Updated Information for Publication 594. Publication An Introduction to Collection Due Process Hearings. Publication Collection Appeal Rights. Publication Installment Agreement Request. Publication How to Prepare a Collection Information Statement (Form 433-A). Publication Making an Administrative Wrongful Levy Claim Under Internal Revenue Code Section 6343(b). Publication Table for Figuring Amount Exempt from Levy on Wages, Salary, and Other Income--Forms 668-W(c), 668-W(c)(DO)and 668-W(ICS). Publication Purchase Money Mortgages and Subordination of the Federal Tax Lien. Publication Instructions for Preparing Notice of Non-Judicial Sale of Property & Application for Consent to Sale. Publication How to Prepare Application for Certificate of Nonattachment of Federal Tax Lien. Publication Instructions on How to Apply for Certificate of Subordination of Federal Tax Lien. Publication How to Apply for a Certificate of Subordination of Federal Estate Tax Lien Under Section 6325(d)(3) of the Internal Revenue Code. Publication Instructions on How to Apply for Certificate of Discharge from Federal Tax Lien. Publication Certificate of Release of Federal Tax Lien. Publication The IRS Collection Process. Notice Updated Information for Publication 594. Publication Instructions on How to Apply for Certificate of Discharge from Federal Tax Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
9 Lien. Publication Bankruptcy Tax Guide. Publication 4681 (2010) - Canceled Debts, Foreclosures, Repossessions, and Abandonments (for individuals). Publication Tax-Exempt Status for Your Organization. Publication Exempt Organization Appeal Procedures for Unagreed Issues. Publication Tax Exempt and Government Entities Division. Publication Exempt Organization's Introductory Brochure. IRS Revenue Rulings (IRS Rev. Rul.) - IRS Revenue Procedures (IRS Rev. Proc.) - IRS Legal Memoranda (IRS ILM) - IRS Technical Advice Memoranda (IRS TAM) - IRS Private Letter Rulings (IRS PLR) - IRS Policy Statement (IRS P) - IRS Chief Counsel (CC) - IRS CC Advice Memoranda (IRS CCAM) - IRS Chief Counsel Advice (IRS ECC) - IRS Field Service Advices (IRS FSA) - IRS Field Attorney Advice (IRS FAA) - IRS Determination Letters (IRS DL) - IRS Notices - IRS Fact Sheets (IRS FS) - IRS Announcements (IRS Ann) - IRS Information Releases (IRS IR) - IRS News Releases (IRS NR) - IRS Small Business / Self-Employed (IRS SB/SE) - IRS Frequently Asked Questions (IRS FAQ) - IRS Program Manager Technical Assistance (IRS PMTA) - Whistleblower Award Paid to Nonresident Alien May Be U.S. Source Income (Tax Notes Today, 2013 TNT /22/2013). IRS Can Withhold Income Tax From Whistleblower Awards (Tax Notes Today, 2011 TNT Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
10 - 03/11/2011). IRS Can Withhold Income Tax From Whistleblower Awards (Tax Notes Today, /30/2010). Whistleblower Can Receive Award for Preventing IRS From paying Refund (Tax Notes Today, /01/2010). IRS Can t Pay Whistleblower Awards From Court-Imposed Criminal Fines (Tax Notes Today, 2011 TNT /22/2010). Other documents - Whistleblower Office Reissues Interim Guidance on Withholding Program, WO (Tax Notes Today, 2013 TNT /07/2013). Whistleblower Office Reissues Interim Guidance on Award Determination Administrative Proceedings, WO (Tax Notes Today, 2013 TNT /07/2013). Whistleblower Office Reissues Interim Guidance Updating Award Procedures, WO Tax Notes Today, 2013 TNT /07/2013). IRS Warns of Sequester Cuts to Whistleblower Awards (Tax Notes Today, 2013 TNT /05/2013). Whistleblower Advocates Criticize Proposed Regs on Whistleblower Award Program (Tax Notes Today, 2013 TNT /19/2013). Law Firm Points Out Need for Changes in Proposed Regs on Whistleblower Award Program (Tax Notes Today, 2013 TNT /16/2013). IRS Whistleblower Office Releases 2012 Report to Congress (Tax Notes Today, 2013 TNT /13/2013). Anonymous Corporate Tax Whistleblower Awarded $38 Million (By Matthew Dalton, Tax Notes Today, 2012 TNT /29/2012). Law Firm Announces $38 Million Reward to Tax Whistleblower (Tax Notes Today, 2012 TNT /26/2012). Firm Supports Changes to Proposed Regs on Payment of Whistleblower Reward (Tax Notes Today, 2011 TNT /18/2011). Firm s Comments Address Proposed Regs on Payment of Whistleblower Rewards (Tax Notes Today, 2011 TNT /18/2011). Group requests Changes to Proposed Regs on Payment of Whistleblower Rewards (Tax Notes Today, 2011 TNT /18/2011). Law Firm Praises $4.5 Million Award in Whistleblower Case (tax Notes Today, 2011 TNT /08/2011). Individual Contends Proposed Whistleblower Regs Don t Reflect Intent (Tax Notes Today, 2011 Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
11 TNT /12/2011). ABA Members Comment on Proposed Amendments to Circular 230 (Tax Notes Today, 2010 TNT /07/2010). Examine the following National Whistleblower Center s Releases - National Whistleblower Release (02/20/2013). Examine the following IRS and TIGTA forms and the instructions thereto - (See IRS Form A - Information Referral (For example, to report tax fraud). IRS Form Application for Award for Original Information. Examine the following articles, letters, reports, etc. from professional individuals or organizations - Which Way the Wind Blows: Mitigating Whistleblowing Risk (By Michael P. Dolan and Timothy J. McCormally, Tax Notes Today, 2013 TNT /24/2013). IRS Formally Denies Whistleblower Award in Insinga Challenge (By Jeremiah Coder, Tax Notes Today, 2013 TNT /19/2013). Reduced Role of Eyeball Test Under FATCA a Challenge for Nonfinancial Institutions (By Jaime Arora, Tax Notes Today, 2013 TNT /19/2013). New Analysis; The Whistleblower Whipsaw Process (By Jeremiah Coder, Tax Notes Today, 2013 TNT /06/2013). Squester Means Reduced Whistleblower Awards, IRS Says (By Jeremiah Coder, Tax Notes Today, 2013 TNT /05/2013). Attorney Says Regs Should Require Periodic Communication Between IRS and Whistleblowers (By Michael L. Sullivan, Tax Notes Today, 2013 TNT /19/2013). Law Firm Criticizes Proposed Regs on Whistleblower Award Program (By Scott A. Knott and Gregory S. Lynam, Tax Notes Today, 2013 TNT /19/2013). Watchdog Groups Say Proposed Regs Could Harm Whistleblower Program (By Angela Canterbury, Michael Smallberg and Tom Devine, Tax Notes Today, 2013 TNT /19/2013). Attorney Suggests Improvements to Proposed Whistleblower Regs (By Bryab C. Skarlatos, Tax Notes Today, 2013 TNT /19/2013). Attorney Suggests Modifying Proposed Regs on Whistleblower Award Program (By Jeffrey A. Nieman, Tax Notes Today, 2013 TNT /18/2013). Law Firm Suggests Changes to Proposed Whistleblower Regs (By Phineas Baxandall and Dan Smith, Tax Notes Today, 2013 TNT /18/2013). Attorney Warns of Adverse Effects of Proposed Whistleblower Regs (By Mark Scott, Tax Notes Today, 2013 TNT /18/2013). Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
12 Attorney Supplements Prior Comments on Proposed Regs on Whistleblower Award Program (By Patrick Carmody, Tax Notes Today, 2013 TNT /17/2013). Law Firm Urges IRS to amend Proposed Whistleblower Regs (By Scott R. Oswald, David Scher and Richard Peterson, Tax Notes Today, 2013 TNT /15/2013). Anti-Fraud Group Responds to proposed Whistleblower Regs (By Kristin Amerling, Tax Notes Today, 2013 TNT /15/2013). IRS report on Whistleblower Awards Shows Slow Growth and Long Waits (By Jeremiah Coder, Tax Notes Today, 2013 TNT /14/2013). Grassley Say IRS Must Do More for Whistleblowers (Tax Notes Today, 2013 TNT /13/2013). IRS Updates Grassley on Whistleblower Efforts (Tax Notes Today, 2013 TNT /11/2013). Letter-Writing Campaign Directs Criticism at Proposed Whistleblower Regs (By George Saba, Tax Notes Today, 2013 TNT /05/2013). Attorney Disheartened by Proposed Whistleblower Regs Suggests Alternatives (By Patrick Carmody, Tax Notes Today, 2013 TNT /03/2013). Proposed Whistleblower Regs Don t Cut it, Grassley Says (By Eric Kroh, Tax Notes Today, TNT /30/2013). Grassley Expresses Whistleblower Concerns to Treasury and IRS (Tax Notes Today, TNT /28/2013). Year in Review: Whistleblowers Were Either Rich of Angry After 2012 (By Jeremiah Coder, Tax Notes Toda, TNT /09/2013). IRS Publishes Proposed Regs Providing Guidance on Whistleblower Award Program (Tax Notes Today, TNT /18/2012). Proposed Whistleblower Regs Detail Computations and Definitions (Tax Notes Today, TNT /26/2012). Government Wins on Required Records Doctrine Draw Protest (Tax Notes Today, 2012 TNT /10/2012). Fight Continues Over Whistleblower Award Eligibility for FBAR Penalties (By Jeremiah Coder, Tax Notes Today, 2012 TNT /28/2012). Whistleblower Referrals Leading to CI, DOJ Investigations (By Shamik Trivedi, Tax Notes Today, 2012 TNT /13/2012). Law Firm Announces $38 Million Reward to Tax Whistleblower (By Ferraro Law Firm Tax Notes Today, 2012 TNT /26/2012). Law Firm Announces $2 Million Reward to Tax Whistleblower (Tax Notes Today, 2012 TNT /04/2012). Former IRS Employee Charged With Conflict of Interest, Exposing Bank Whistleblower (By Eric Kroh, Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
13 Tax Notes Today, 2012 TNT /01/2012). IRS Pays Birkenfield $104 Million Whistleblower Award (By Jeremiah Coder, Tax Notes Today, 2012 TNT /12/2012). IRS Summary Award Report Recommends $104 Million Payment to Whistleblower (Tax Notes Today, TNT TNT Undated). National Whistleblowers Center Announces $104 Million IRS Award (Tax Notes Today, 2012 TNT /11/2012). Whistleblower Tips a Big Help in IRS s International Criminal Enforcement (Tax Notes Today, 2012 TNT /16/2012). National Whistleblowers Center Recommends IRS Revise Interpretation of Planned and Initiated Tax Notes Today, 2012 TNT /03/2012). National Whistleblowers Center Announces Prison Release of UBS Bank Whistleblower (Tax Notes Today, 2012 TNT /01/2012). Firm Comments on Proposed Changes to Whistleblower Award Determination Administrative Proceedings (Tax Notes Today, 2012 TNT /31/2012). Grassley Lifts Hold on Nominees, Says IRS Must Do More for Whistleblowers (Tax Notes Today, 2012 TNT /30/2012). IRS s Miller Responds to Grassley on Whistleblower Questions (Tax Notes Today, 2012 TNT /25/2012). Treasury Responds to Grassley s Request for Whistleblower Program Status (Tax Notes Today, 2012 TNT /25/2012). Grassley Suggests Statutory Changes May Be Needed for Whistleblower Program (Tax Notes Today, 2012 TNT /20/2012). Whistleblower Awards Cant Be Based on Non-Tax Laws, IRS Advises (Tax Notes Today, 2012 TNT /16/2012). IRS Respond to Grassley s Whistleblower Program Concerns (Tax Notes Today, 2012 TNT /16/2012). Treasury s McMahon Says Proposal Regs on Whistleblowers Are Coming (Tax Notes Today, 2012 TNT /13/2012). National Whistleblower Center Files Amicus Brief in Tax Court Whistleblower Case (By Jeremiah Coder Tax Notes Today, 2012 TNT /27/2012). IRS Whistleblower Office Report Cites Lower Submissions, Awards (Tax Notes Today, 2012 TNT /22/2012). IRS Sets Timelines for Action Whistleblower Claims (By Jeremiah Coder, Tax Notes Today, 2012 TNT /22/2012). Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
14 Grassley Seeks More Information From IRS, Treasury on Whistleblower Program (Tax Notes Today, 2012 TNT /21/2012). IRS Whistleblower Office Post 2011 Report Website (Tax Notes Today, 2012 TNT /21/2012). Suggested Amendments to the Tax Whistleblower Statute (By Bradley D. Kay, Tax Notes Today, 2012 TNT /12/2012). Whistleblower Office Issues Interim Guidance on Award Determination Administrative Proceedings (Tax Notes Today, 2012 TNT /07/2012). Report Certain Foreign Bank and Financial Accounts to Treasury by June 30 (IR News Release 06/24/2011). Tax Court Can t Force IRS To Reconsider Whistleblower Award Denials (By Jeremiah Coder, Tax Notes Today, 2011 TNT /21/2011). IRS Withholding on Whistleblower Awards Ignites Controversy (By Jeremiah Coder, Tax Notes Today, TNT /22/2011). IRS Pays First Enhanced Whistleblower Award (By Jeremiah Coder, Tax Notes Today, TNT /11/2011). Comments On Proposed Revisions To Treasury Regulation (By Kenneth H. Ryesky, Esq., Tax Notes Today, 2011 TNT /05/2011). Law Firm Suggests Changes To Proposed Regs On Payment Of Whistleblower Rewards (Tax Notes Today, 2011 TNT /28/2011). Individual Comments On Proposed Regs. On Payment Of Whistleblower Rewards (Tax Notes Today, 2011 TNT /23/2011). Firm Seeks Clarifications Under Proposed Regs on Payment of Whistleblower Reward (By Linda J. Stengle, Tax Notes Today, 2011 TNT /23/2011). On-Line IRS Form 3949-A And Instructions For Completing And Sending The Form To The IRS - 5LcCFaYWMgodOhwASQ Examine the following documents by Professor Jegen - (These documents will be distributed in class). Copyright 1986 Through 2014, Professor Jegen s Taxsite F-2000 EH 893 Course Assignments
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