Does the IRS Have The Authority to Issue Whistleblower Awards For FBAR Penalties?
Does the IRS have the authority to issue Whistleblower awards under Section 7623(b) to an individual who provides information that results in the assertion of FBAR penalties? In Whistleblower 22231-12W v. Commissioner, T.C. Memo. 2014-157, the Tax Court came close to deciding this issue. The only reason it stopped short was because the jurisdictional pre-requisite […]