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Whistleblowers: Nuts, Bolts, and the Pay-Off

ABA Tax Times

In this article, Tyler Jackson summarizes the panel he moderated at the American Bar Association (ABA) Tax Section's Criminal Tax Fraud and Tax Controversy Conference in December 2025, titled "Whistleblowers: Nuts, Bolts, and the Pay-Off." The article examines recent developments in the Internal Revenue Service (IRS) whistleblower program, including significant award payments and new leadership at the IRS Whistleblower Office. Drawing on insights from experienced government officials and private practitioners, Jackson highlights practical considerations for whistleblower claims, including what makes a strong submission, the importance of documentation, managing client expectations in a lengthy and opaque process, and navigating IRS, Department of Justice (DOJ), and Tax Court procedures.