IRS Whistleblower Program Improvement Act

• •Establishes that Tax Court reviews of whistleblower award determinations must be 'de novo' based on the administrative record and any new evidence.
• •Mandates that whistleblowers proceed anonymously in Tax Court unless the court finds a societal interest in disclosure that outweighs potential harm to the whistleblower.
• •Requires the IRS to pay interest on whistleblower awards if a preliminary award recommendation is not provided within 12 months of the 'applicable date' (when tax proceeds are collected and liabilities are finalized).
• •Interest payments on awards will cease once the IRS provides notice of a preliminary award recommendation.
• •Requires the annual IRS whistleblower report to include a list and description of the top 10 tax avoidance schemes disclosed by whistleblowers that year.
• •Expands the scope of attorney's fee deductions to cover all whistleblower actions under section 7623, rather than just those under 7623(b).
• •The interest payment provisions take effect 180 days after the bill is enacted.
• •The Tax Court review and privacy provisions apply to all petitions pending on or filed after the date of enactment.

This bill changes the legal rights and potential financial compensation for individuals who report tax evasion to the IRS, specifically by allowing interest on delayed awards and mandating anonymous proceedings in Tax Court.

Patterns POLISCOPE noticed across the record. These are observations to investigate, not conclusions.