Attorney-at-Law

BONUS POOL?

In Uncategorized on 10/16/2024 at 19:35

Cases like Whistleblower 20442-18W, filed 10/16/24, make we wonder if there’s a bonus pool for the Ogden Sunseteers, John (“Hoppin’ John”) Hinman’s hardlaboring crew. Memories of days long gone, when I sat in partners’ meetings debating how much guided largesse to strew among the Cratchits who billed the hours that made the year a banner year, brought that question to mind.

Perhaps there’s a category in this imaginary pool for “Best Award Recommendation” memorandum weasel-wording. 20442-18W offers this gem: “the exam teams made adjustments to several issues related to the whistleblower allegations.” Order, at p. 5. But none of those allegations were substantial contributions to IRS’ efforts; IRS had identified the issues already.

So no award.

OK, identifying issues is necessary, but it isn’t sufficient. Once identified, what specific items give rise to a deficiency? Example, with imaginary facts unrelated to this case: IRS suspects unreported income, identifies issue. Reviews bank accounts, brokerage accounts, bitcoin, nominee accounts, office petty cash drawer, all yield nothing. Everything there reported. Whistleblower says “bags of cash in corporate secretary’s basement behind the hot water heater.” Adjustments made.

OK, we haven’t the facts in this case. The order deals with a discovery demand that has largely been satisfied last year, says Judge Albert G. (“Scholar Al”) Lauber. The rest is silence.

But still, I wonder if there’s a bonus pool.

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