The Law Offices of Paul D. Scott, P.C. has been representing whistleblowers before the IRS since prior to the new whistleblower program being introduced in 2006. Since the creation of the new whistleblower program, Mr. Scott has been repeatedly consulted by the IRS, at meetings with the head of the IRS whistleblower office and numerous other IRS officials, regarding the operation of the whistleblower program and the regulations and guidance governing it. He has also been asked by the IRS to lecture to IRS personnel about the whistleblower program, and he has been involved at various times as a speaker, moderator and/or co-organizer of conferences with IRS officials and others to educate attorneys about the program.
The Law Offices of Paul D. Scott, P.C. has had success with the IRS whistleblower program and currently has claims pending involving allegations of billions of dollars in unpaid taxes.
The Internal Revenue Service is permitted under Section 7623 of the Internal Revenue Code to pay rewards to whistleblowers who provide information leading to the recovery of funds from those who underpay taxes to the United States government. There are two main programs to consider:
In December 2006, a new law went into effect that dramatically strengthened the IRS’s whistleblower program. Under the new program, qualified whistleblowers may be entitled to awards of up to 30% of funds that are recovered by the IRS based on information provided by the whistleblowers regarding tax schemes exceeding $2 million.
The old Form 211 program permitted whistleblowers to request rewards from the IRS after reporting information about individuals or entities who have underpaid taxes. Notably, however, payment of any reward by the IRS under the former Form 211 procedure is within the government’s discretion and cannot be compelled by the whistleblower. This program (now referred to as the 7623(a) program) is still available for claims not large enough to qualify for the increased rewards under the new IRS Whistleblower Program.
The IRS historically maintained a lesser known program commonly referred to as its Special Agreement program. The Special Agreement program provided more certainty to whistleblowers than the old Form 211 program, for it permitted them to enter into a contract with the IRS in advance of providing detailed information about the subject taxpayer and their alleged tax violations. The Special Agreement program, however, has now been replaced by the foregoing claims-based programs.
The Law Offices of Paul D. Scott offers confidential consultations at no charge regarding potential claims involving underpayments of tax in excess of $2,000,000.
Please be advised that this website is an information resource and is not intended to provide legal advice in your particular case. We would be pleased to conduct a confidential review of your potential claim, but by doing so we are not agreeing to act as your counsel. A written agreement between you and the Law Offices of Paul D. Scott is prerequisite to representation. Past successes by the firm do not guarantee future results.
The Law Offices of Paul D. Scott, P.C.
Pier 9, Suite 100, The Embarcadero
San Francisco, CA • 94111
Tel: 415-981-1212 • Fax: 415-981-1215