Defining “Collected Proceeds” Under the IRS’s Whistleblower Program

November 16, 2017  |  New York Law Journal

Information from whistleblowers has generated billions of dollars in revenues for the IRS and hundreds of millions of dollars for whistleblowers. This article discusses Whistleblower 21276-13w v. Commissioner of Internal Revenue, in which the United States Court of Appeals for the D.C. Circuit will review the Tax Court’s determination that awards should be based on the entire amount the government recovers based on a whistleblower’s information. While the IRS has argued that awards should be limited to amounts recovered under the Internal Revenue Code, others worry that excluding recoveries under other statutes could hamper the IRS’s enforcement efforts.

Defining “Collected Proceeds” Under the IRS’s Whistleblower Program (pdf | 222.32 KB)