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OnDemand Course

IRS Whistle-Blowers ... Is it Worth it to Blow the Whistle?

Find out what to expect and the risks of whistle-blowing to the IRS.

When Congress implemented its latest version of the IRS Whistle-Blower Program in 2006 and created the IRS Whistle-Blower Office, the thought was that this was going to provide huge incentives for people to come forward and lower the large tax gap that exists in this country's voluntary tax system. While the money-mandating aspects of the new law were a much needed improvement on the prior, purely discretionary system utilized by the IRS, the new law seems to have failed in many respects. For starters, the new IRS whistle-blower law does not expressly protect IRS whistle-blowers from retaliation, nor does it prevent the IRS from continuing to employ means by which to avoid having to make any payment of any award. Concerns remain that some parts of the IRS view whistle-blowers as akin to skunks at a picnic. Whistle-blowers otherwise seeking to vindicate their perceived right to an award will soon find that privacy concerns for the targeted or identified taxpayer will greatly complicate pursuit of the same. On top of that, whistle-blowers must understand the significant risks that go into whistle-blowing activities. The whistle-blower must be able to withstand the adversity that comes from such activities and be prepared to defend against actions taken back against them by the taxpayers they have targeted. In the end, absent much needed reform, one may legitimately ask, is it worth it? At a minimum, it is imperative that those who do decide to come forward and blow the whistle to the IRS do so with their eyes wide open as to the risks of doing so, and not be blinded by the lure of a possible, but far-too-rare, award.

Runtime: 96 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

How the IRS Whistle-Blower Program of Today Came Into Being

  • The IRS Informant Claims Program (Prior to December 20, 2006)
  • Special Agreements (Prior to December 20, 2006)
  • The IRS Whistle-Blower Program as Enacted by the Tax Relief and Health Care Act of 2006 (New Section 7623)

What to Expect When One Blows the Whistle to the IRS

  • Perceptions of the IRS Whistle-Blower
  • Psychology of the IRS Whistle-Blower
  • Legal Protection of the IRS Whistle-Blower
  • Famous IRS Whistle-Blowers

Overview of IRS Procedures for Whistle-Blowing (IRM 25.2.2)

  • IRS Whistle-Blower Office
  • IRS Form 211
  • Other Contacts Made With IRS
  • Distinguishing 7623(a) and 7623(b) Claims
  • The Debriefing of Whistle-Blowers and the IRS' One-Bite Rule
  • Recovery and Taxability of Any Award

The Risks of Whistle-Blowing to the IRS

  • Taxpayer Privacy Concerns
  • Confidentiality of Whistle-Blower Submissions
  • Taxpayer Actions Back Against the IRS Whistle-Blower
  • Witness Protection and Other Obligations or Duties of the IRS

Litigating Whistle-Blowing Claims

  • IRS Determination of Eligibility for Award
  • Petitions Filed in the United States Tax Court
  • Discovery Issues and the Administrative Record
  • Latest Case Law Developments

Future of IRS Whistle-Blowing

  • Possible Reforms
  • Final Observations - Is It Worth It?
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on March 22, 2016.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

T. Scott Tufts, Esq.

T. Scott Tufts, Esq.

CPLS, P.A.

  • Senior tax counsel, CPLS, P.A.
  • Practice emphasizes helping clients who are faced with the filing of certain IRS forms that lead to disputes, as well as tax disputes with the IRS, probate and Federal and state court disputes involving partners and members and estates
  • Practice areas include the handling of IRS tax disputes, expert witnessing, and consultation with partners, members, and their practitioners that pertain to IRS Forms 8082 (notice of inconsistent treatment and erroneous K-1s), as well as IRS Forms 8886 (Reporting of Abusive Tax Shelters), SS-8 (worker classification), 1099-MISC (independent contractors), W-2c/ Form 4852 (Substitute Form W-2 or Form 1099-R); Form 211 (whistleblowers), Form 3949-A (referral of alleged violations of the tax laws), Form 14242 (suspected abusive tax promotions or promoters), Form 14039 (stolen identity and use of your SSN), Form 14157 (reporting of fraud or abusive tax scheme by preparer), Form 13909 (reporting of suspect misconduct or wrongdoing of tax exempt or employee plan)
  • Conducts regular seminars and workshops on areas focused on whistleblowers and the handling of IRS disputes, as well as in the areas of probate and tax, and partnership and LLC matters
  • Wrote several publications: “Evaluating LLC Operating Agreements Containing “Carte Blanche” Authority and Right to Rely Provisions Purporting to Release Third Parties from Any Duty to Inquire,” Tax Section Bulletin, Florida Bar, Tax Section, Vol. XXIX, No. 2, p. 7, 10-26 (Fall 2013); “AD Global and the Statute of Limitations for TEFRA Partnerships: Will the TMP Ever Have to Stop Looking in the Rear View Mirror for the IRS” Tax Section Bulletin, Florida Bar, Tax Section, Vol. XXIV, No.2, p.14, pp.25-29 (February 2006); “It Ain’t Over ‘Til Its Over: When Partnership Tax Vessels Make Ill-Advised Journeys and Wind-Up at Harbor Cove Marina” Journal of Business Entities (September/October 2004); “What IRS Form 8082 Can Do For You (and to you!) and Your Closely-Held Partnership Now that the IRS’ K-1 Matching Program is Underway” BNA Tax Management Real Estate, Vol. 19, No. 12 (December 3, 2003); “Are Single-Member LLCs a Ticking Time-Bomb for Asset Protection?” (Are Single-Member LLCs of Any Utility for Asset Protection after the Florida Supreme Court’s Decision in Olmstead?) (ABA Teleconference, August 24, 2010)
  • LL.M. degree, taxation, University of Miami School of Law; J.D. degree, Wake Forest University School of Law; B.S. degree, accounting, Florida State University
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Product ID: 397423
Published 2016
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