Originally published:
Wolters Kluwer, Journal of Tax Practice & Procedure, Vol. 26, No. 4, Winter 2024
The modern Internal Revenue Service (“IRS”) whistleblower program, put in place in 2006 with the creation of Code Sec. 7623(b), is undergoing a significant administrative overhaul as well as enjoying marked support from senior management at the IRS. Much is changing in the awards program, with the overall result being a fresh new welcome mat for whistleblowers to come forward with information. While not everything is sunshine and roses for the program, certainly brighter days are ahead.
This article provides an overview of the new leadership and proposed administrative reforms at the IRS Whistleblower Office (“WBO”); the trend in awards to whistleblowers; current interests of the IRS as to information from whistleblowers; the possible impact of various IRS whistleblower cases, including the Lissack case before the D.C. Circuit after the Supreme Court decision in Loper Bright; and, the outlook for proposed legislation and other reforms.