Whistleblower Bradley Birkenfeld, whose $104 million reward from the U.S. Internal Revenue Service set a record three weeks ago, has helped set off a rush of would-be imitators hoping to cash in on a government program to catch tax cheats. Birkenfeld, now living in New Hampshire, helped lead the IRS to collect hundreds of millions…
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Government May Attach Lien to Half-Interest in Property Held in Tenacy by the Entirety.
The U.S. Court of Appeals for the Sixth Circuit, on Aug. 6, affirmed a district court's judgment that concluded that the government's federal tax lien that arises by operation of law in “all property and rights to property” of a delinquent taxpayer (26 U.S.C. 6321) attaches to the rights of that taxpayer in property held…
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No IRS Whistleblower Awards for Non Title 26 Tax Violations
Violations of non-tax laws—including those enforced by the Internal Revenue Service—cannot form the basis of a whistleblower award under tax code Section 7623, the IRS Office of Chief Counsel said in a program manager technical advice memorandum. This memorandum (PMTA 2012-10 ) addresses whether I.R.C. § 7623 authorizes payment of whistleblower awards based on information…
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District Court – Bankruptcy Court Cannot Enjoin IRS's Future Exercise of Rights to Setoff & Recoupment
The U.S. District Court for the Eastern District of New York ruled Sept. 15, 2012, that A bankruptcy court has no jurisdiction to enjoin the Internal Revenue Service's future exercise of its rights to setoff and recoupment. Relivant portions of the Decision … VI. Recoupment and Setoff The final dispute at issue in this…
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