This course will provide an overview of the whistleblower statute, how to prepare and file a Form 211, Application for Award for Original Information, which factors will lead to an award (and which will lead to the reduction of an award); and how to challenge the IRS’s determinations regarding your application and/or award.
Learning Objectives:
Withers Bergman LLP
Senior Associate
[email protected]
Phil is a senior associate at Withers Bergmen LLP (Withers Worldwide). Phil’s practice is focused on domestic and international tax controversy. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and, if necessary, at the appellate level.
Phil has spoken on various tax topics and at various forums, including the American Bar Association, New York County Lawyers' Association, IRS Nationwide Virtual Tax Forum, CPA Academy, and NYU Tax Controversy Forum. He has also published several tax-related articles, which have been published by Tax Notes, Bloomberg BNA, Journal of Tax Practice and Procedure, EA Journal, and The Practical Lawyer. In addition to his publication and speaking engagement, he is heavily involved with the American Bar Association, where he is the incoming Chair of the Tax Collections Bankruptcy and Workouts Committee.