- The change in the statute from "collected proceeds" to "proceeds" with a broadening of the base for whistleblower awards to clearly encompass non Title 26 collections (such as FBAR penalties and criminal fines related to tax crimes).
- The scope of review for Tax Court whistleblower cases.
- Appellate venue to the D.C. Circuit Court of Appeals for Tax Court whistleblower cases.
- The WBO's fye 2017 statistics for whistleblower cases.
Jack Townsend offers this blog in conjunction with his Federal Tax Procedure Books, currently in the 2019 editions (Student and Practitioner). Annual editions of the books are published in August. Those books may be downloaded from SSRN (see the page link in the top right hand column of this blog title 2019 Federal Tax Procedure Book & Updates). In addition, Jack uses this blog to discuss issues of federal tax procedure.
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Saturday, April 21, 2018
Whistleblower Matters - Update (4/21/18)
I have made updates to the working draft of the Federal Tax Procedure book based, in part, on a recent posting on the Procedurally Taxing Blog -- Keith Fogg, Don’t Expect a Whistleblower Award for Giving the IRS Privileged Information and General Information from the Judicial Conference on this Issue (Procedurally Taxing Blog 4/16/18), here. Also included in the updates are the recent statutory changes to the whistleblower awards program. I link here a pdf of a red-line of the Whistleblower chapter -- Chapter 19. Whistleblower Awards -- showing the changes in the working draft from the 2018 edition. This is a footnoted edition of the draft of the chapter. The principal new items covered are:]
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