Resources and Legal Authority
International Tax Whistleblower Representation
IRS Whistleblower Statute
IRS Manual Whistleblower Provisions
IRS Regulations, Notices and Memos
- Chief Counsel Notice CC-2010-004 This Notice modifies Notice CC-2008-011 by loosening the limitations on the IRS's ability to contact informants who are current employees of a taxpayer.
- IRS Memo SBSE-04-0909-054 Internal IRS procedures for processing cases to be analyzed by the IRS Small Business/Self-Employed Division.
- IRS Memo LMSB-4-1108-052 Internal IRS procedures for processing cases to be analyzed by the IRS Large and Mid-Size Business Division.
- Chief Counsel Notice CC-2008-011 "Limitations on Informant Contacts: Current Employees and Taxpayer Representatives"
- IRS Notice 2008-4 This Notice provides guidance to the public on how to file claims under Internal Revenue Code section 7623 as amended by the Tax Relief and Health Care Act of 2006.
- Chief Counsel Notice: CC-2008-001 This Notice provides guidance relating to a new cause of action in the Tax Court for review of award determinations made by the Service's Whistleblower Office, pursuant to section 7623.
- Section 7623
- Treasury Regulation 301.7623-1 (based on the old Informant's Rewards Program).
TAX Court Cases
- Cooper v. Commissioner, 135 T.C. No. 4 (July 8, 2010) (The Tax Court held that the IRS’s “No Answer” letter denying a whistleblower claim was a determination by the Service conferring jurisdiction on the Tax Court for the purpose of appeal under Sec. 7623(b)(4), I.R.C.).
- Amended Tax Court Rules re Whistleblower Actions United States Tax Court Washington, D.C., October 3, 2008 Press Release
- Dacosta v. United States , No. 07-807T (Jul. 11, 2008) (The Court of Federal Claims dismissed actions against the government for whistle-blower rewards finding that the Tax Court has sole jurisdiction, there is no contractual claim, and transfer of the case to the Tax Court is not statutorily permissible.)
- Wolf v. Commissioner, T. C. Memo 2007-133 (May 30, 2007) (The Tax Court denied an untimely request for a reward under the tax whistleblower provisions).
