Whistling Dixie About the IRS Whistleblower Program Thanks to the IRC Confidentiality Restrictions

65 Pages Posted: 21 Feb 2010  

Michelle M. Kwon

University of Tennessee College of Law

Date Written: February 20, 2010

Abstract

The Internal Revenue Service has been authorized for many years to pay awards to individuals who blow the whistle on those who do not pay their taxes. But the whistleblower program was underused and ineffective. In 2006, Congress modified the whistleblower program to boost the IRS’s authority to pay cash awards to tax whistleblowers. The premise of the article is that Congress did not go far enough in 2006 in light of the confidentiality restrictions in Internal Revenue Code Section 6103. As currently written, Section 6103 essentially prohibits the IRS from disclosing to the whistleblower tax information of the purportedly non-compliant taxpayer upon whom the whistle was blown, which creates at least three problems that the article addresses. The article examines the tension between the confidentiality provisions in Section 6103 and the IRS’s whistleblower program and attempts to balance the competing interests of taxpayer privacy and tax administration.

Keywords: Whistleblower, IRC 6103, Internal Revenue Service, Taxpayer, Tax Administration

JEL Classification: K34

Suggested Citation

Kwon, Michelle M., Whistling Dixie About the IRS Whistleblower Program Thanks to the IRC Confidentiality Restrictions (February 20, 2010). Virginia Tax Review, Forthcoming; Texas Tech Law School Research Paper No. 2010-01. Available at SSRN: https://ssrn.com/abstract=1556370

Michelle M. Kwon (Contact Author)

University of Tennessee College of Law ( email )

1505 West Cumberland Avenue
Knoxville, TN 37996
United States

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