Submissions that do not qualify under 7623(b) will be processed under section 7623(a).
- These cases will continue to be considered through regulations appearing at 26 CFR 301.7623-1.
- The award is at the discretion of the Service, there is no requirement that an award be issued.
The discretionary award is based on additions to tax, penalties, interest, and other amounts collected as a result of administrative or judicial action resulting from the information provided.
No minimum statutory award percentage
No appeal provisions