Tax News

CCH (cch.taxgroup.com) reports:

The IRS has issued interim guidance regarding filing claims with the Whistleblower Office pursuant to Code Sec. 7623, in light of the changes brought by the Tax Relief and Healthcare Act of 2006 (P.L. 109-432), which added Code Sec. 7623(b). The existing regulations, which address only the provisions of Code Sec. 7623(a), are inconsistent with Code Sec. 7623(b). Today's guidance clarifies that these regulations will not apply to the award program authorized by Code Sec. 7623(b).
Under Code Sec. 7623(b), individuals are eligible for awards based on the amount collected by the IRS and the total amount in dispute must exceed $2,000,000 and, if the noncompliant person is an individual, that individual's gross income must exceed $200,000. The amount of the award will be a minimum of 15 percent and a maximum of 30 percent of the collected proceeds. Individuals should complete IRS Form 211, Application for Award for Original Information. The guidance also includes examples of grounds under which claims will not be processed, information regarding confidentiality and IRS processes for evaluating the claim, tax treatment of the awards and rights of appeal.
Claims that do not qualify under Code Sec. 7623(b) may still qualify under Code Sec. 7623(a). This guidance is effective as of January 14, 2008. Comments are requested, and should be submitted on or before February 13, 2008.
IR-2007-201, 2008FED ¶46,207
Notice 2008-4, 2008FED ¶46,208
Other References:
Code Sec. 7623
CCH Reference - 2007FED ¶42,957.021
CCH Reference - 2007FED ¶42,957.12
CCH Reference - 2007FED ¶42,957.15
CCH Reference - 2007FED ¶42,957.30
Tax Research Consultant
CCH Reference - TRC IRS: 63,060.05