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Tax Whistleblowers: Prevention and Mitigation of Costs Associated With Meritless Claims

The Tax Executive

Section 7623 of the Internal Revenue Code, amended by Congress in December 2006, establishes awards for whistleblowers of between 15 and 30 percent of the tax interest and penalties recovered based on their tips. According to the authors, since there is no requirement that the whistleblower’s tip uncover fraud or mal-intent, simply underpayment, this leaves the door open for individuals trying to make money by exposing non-malicious corporate mistakes.  This article was co-authored by Brian Hill, George Clarke and David Blair.