Law Firms Announce Two Significant Tax Whistleblower Awards
Washington, D.C. October 1, 2024. The law firm of Kohn, Kohn & Colapinto and the law firm of Zerbe, Miller, Fingeret, Frank & Jadav – working together at the Tax Whistleblower Attorney Group (TWAG) – announced two tax whistleblower awards today that were made by the Internal Revenue Service (IRS) to their clients. The two awards, a testament to the IRS’s commitment to tax enforcement, total over $14.3 million and reflect over $56 million in taxes returned to the Treasury. Of particular note, one of the awards is thanks to a rare victory for a whistleblower in Tax Court – 18152-17W v. CIR.
Stephen Kohn of Kohn, Kohn & Colapinto said as to the first award, “I am extremely pleased that we were able to secure this success for our client – an award of $12.2 million for the whistleblower’s critical work in helping the IRS recover over $50 million in taxes. Thanks to the whistleblower’s efforts, the IRS collected millions of dollars from millionaires seeking to evade the tax laws. I join Dean in commending the whistleblower for their dedication and determination in coming forward.”
Dean Zerbe of Zerbe, Miller, Fingeret, Frank & Jadav said, “I am especially appreciative of the leadership of the Director of the IRS Whistleblower Office (WBO), Mr. John Hinman, and his team in helping make this award happen. The support the WBO has received from then-IRS Commissioner Charles Rettig and current IRS Commissioner Danny Werfel has been instrumental in helping the WBO make strides in putting out the welcome mat for tax whistleblowers. Also, thanks also to the IRS examiners who recognized the value of the whistleblower’s information and took action. It is clear that the IRS is welcoming of tax whistleblowers with good information about wealthy individuals and businesses evading tax.”
Kohn and Zerbe have jointly represented several tax whistleblowers – including Brad Birkenfeld, the UBS whistleblower who received an award of $104 million from the IRS in 2012. Together, Kohn and Zerbe have realized over $450 million dollars in awards to tax whistleblowers. In addition, they successfully represented the whistleblowers in the landmark Tax Court case Whistleblower 21276-13W v. IRS (147 TC 121(2016)), which resulted in a major win for tax whistleblowers with the expansion of the definition of “collected proceeds” to include criminal fines and civil forfeitures for whistleblower awards. Zerbe and Kohn represent tax whistleblowers through the Tax Whistleblower Attorney Group – TWAG.
Regarding the second whistleblower award, Dean Zerbe, the lead attorney in Whistleblower 18152-17W v. CIR, stated: “It has not been easy in recent years for tax whistleblowers to succeed in Tax Court. I am very pleased that on remand, thanks to the good faith review by the IRS Chief Counsel and the Whistleblower Office, we were able to realize such a good result for the whistleblower. It was a long-dogged journey but worth it in the end. The whistleblower went from zero to getting a 30% award – over $1.9 million dollars – based on $6.3 million in taxes collected from a medium-sized company. I commend the whistleblower for his enormous courage – working closely with IRS criminal investigation, including wearing a wire. The whistleblower was critical in helping the IRS successfully pursue this complicated evasion of taxes. The award is well-deserved.”
Stephen Kohn said, “I congratulate Dean for once again achieving a hard victory in Tax Court on behalf of tax whistleblowers. Such wins are good for all tax whistleblowers and the vast majority of honest taxpayers who pay their fair share. Nothing does more to bolster and strengthen the tax whistleblower program than making awards. Further, it is becoming more and more clear that a successful tax whistleblower program not only helps the IRS go after wealthy tax cheats but, as shown in a recent study in Management Science, a successful tax whistleblower program also deters people from cheating on their taxes in the first place.” See The Deterrence Effects of Tax Whistleblower Laws: Evidence from New York’s False Claims Acts” by Yoojin Lee et al, Management Science, August 14, 2024.
Dean Zerbe said, “The wins for tax whistleblowers that Steve and I announced today are certainly thanks to a team effort. Steve and I – and more importantly, the whistleblowers we represent – benefit from having on our team David Colapinto, with years of experience representing whistleblowers, Steve Miller, the former- Commissioner of the Internal Revenue Service, Eric Hylton, former Deputy Chief of Investigations at IRS Criminal Investigation as well as our capable attorneys Al La Neve and Matthew Beddingfield.”
