Whistleblower 22716-13W v. Comm'r
United States Tax Court
P filed Form 211, Application for Award for Original Information, with the IRS Whistleblower Office with respect to TP1. By guilty plea, TP1 agreed to pay an FBAR civil penalty substantially in excess of $2,000,000 and a small amount of restitution, reflecting unpaid Federal income tax on income derived from Swiss bank accounts.
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P filed Form 211, Application for Award for Original Information, with the IRS Whistleblower Office with respect to TP1. By guilty plea, TP1 agreed to pay an FBAR civil penalty substantially in excess of $2,000,000 and a small amount of restitution, reflecting unpaid Federal income tax on income derived from Swiss bank accounts. A whistleblower is eligible for a non discretionary award under I.R.C. sec. 7623(b) only "if the tax, penalties, interest, additions to tax, and additional amounts in dispute exceed $2,000,000." I.R.C. sec. 7623(b)(5)(B). FBAR civil penalties are imposed and collected…
1Opinion of the Court
WHISTLEBLOWER 22716-13W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Whistleblower 22716-13W v. Comm'r
Docket No. 22716-13W
United States Tax Court
146 T.C. 84; 2016 U.S. Tax Ct. LEXIS 7; 146 T.C. No. 6;
March 14, 2016, Filed
An appropriate order and decision will be entered for respondent.
P filed Form 211, Application for Award for Original Information, with the IRS Whistleblower Office with respect to TP1. By guilty plea, TP1 agreed to pay an FBAR civil penalty substantially in excess of $2,000,000 and a small amount of restitution, reflecting unpaid Federal income tax on income…
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