Applicable Internal Revenue Code (IRC) sections
- : Authorization to pay awards. In addition to providing the authorization for paying awards, this section also contains laws for awards, definition of proceeds, and civil action to protect against retaliation.
- : Under section 6103(a), returns and return information are confidential, unless an exception applies.
- Section 6103(h)(4) authorizes the disclosure of returns and return information in administrative or judicial proceedings pertaining to tax administration in certain circumstances. A whistleblower administrative proceeding under section 7623 is an administrative proceeding under section 6103(h)(4).
- Section 6103(k)(13) authorizes certain disclosures to whistleblowers including notification when the whistleblower¡¯s information has been referred for an audit or examination, notification when a payment of tax has been made on an assessment related to the whistleblower¡¯s information, and information on the status and stage of the investigation or action related to the whistleblower¡¯s information.
Applicable
These regulations provide comprehensive guidance for the award program authorized under Internal Revenue Code (Code) section 7623.
- 26 CFR 301.6103(h)(4)-1: This regulation outlines authorized disclosure of returns and return information in whistleblower administrative proceedings.
- 26 CFR 301.7623-1: This regulation provides general rules for submitting information on underpayments of tax or violations of the internal revenue laws and filing claims for award.
- 26 CFR 301.7623-2: This regulation defines key terms for purposes of determining awards under section 7623 and the corresponding regulations
- 26 CFR 301.7623-3: This regulation describes the administrative proceedings applicable to claims for award under both section 7623(a) and section 7623(b) and appeals of award determinations.
- 26 CFR 301.7623-4: This regulation provides the framework and criteria that the Whistleblower Office will use in exercising the discretion granted under section 7623 to make awards.