Section 7623 of the Internal Revenue Code (the
"Code"), added in 1954, authorizes the Treasury Secretary
to pay an award as he deems necessary for "(1) detecting
underpayments of tax, or (2) detecting and bringing to trial and
punishment persons guilty of violating the internal revenue laws or
conniving at the same." The program was significantly
enhanced in 2006 as part of the Tax Relief and Health Care Act with
the addition of Code section 7623(b), which provides that if the
Treasury Secretary proceeds with any action based on
information brought to the Secretary's attention by an
individual, such individual will receive as an award at least 15%
but not more than 30% of the collected proceeds (including
penalties, interest, additions to tax, and additional amounts)
resulting from the action (including any related actions) or from
any settlement in response to such action. The determination
of the amount of such award by the IRS Whistleblower Office, which
was
