# H.R. 7959 (119th): IRS Whistleblower Program Improvement Act

IRS Whistleblower Program Improvement Act This bill modifies provisions of the Internal Revenue Code relating to whistleblower awards and protections. Specifically, the bill revises the standard for review of whistleblower awards in the Tax Court to require a de novo review (rather than the current abuse of discretion review) based on the administrative record established at the time of the whistleblower award determination and any new or previously unavailable evidence, allows whistleblowers anonymity in proceedings before the Tax Court (unless a societal interest in disclosing a whistleblower's identity outweighs potential harm to the whistleblower), modifies the Internal Revenue Service (IRS) whistleblower report to require inclusion of a list and description of up to 10 of the top tax avoidance schemes disclosed by whistleblowers, and requires payment of interest on mandatory whistleblower awards if the IRS fails to provide timely notice to a whistleblower of an award recommendation. The bill also allows payments of the attorney fees of whistleblowers to be deducted when calculating adjusted gross income for tax purposes regardless of whether the whistleblower award was paid through the mandatory or the discretionary whistleblower award program. (Under current law, the deduction is limited to attorney fees paid in connection with mandatory awards.)

## How this bill is scored

Tier: no Tier 1 record. A bill with no record cannot newly become Tier 1.
Lane: abuse_accountability. Category: justice_truth. Lane tag: general equity.
Lane: administrative_procedure. Category: not stored. Lane tag: not stored.
Lane: civil_forfeiture_abuse. Category: not stored. Lane tag: not stored.
Lane: tax_policy. Category: not stored. Lane tag: not stored.
Lane: whistleblower_protection. Category: justice_truth. Lane tag: general equity.
Tier 1 sign-off: no record. A bill with no record cannot newly become Tier 1.
Stored polarity: mixed. Only tags the rules mark scoreable on a mixed bill are scored. A yea can draw a penalty or a credit according to the tag. A nay on a tag scored as good can draw a penalty.
Roll 138: On Motion to Suspend the Rules and Pass, as Amended. Vote type: final_passage.
Polarity rationale: Reviewed enrichment (llm_import) polarity: The bill combines goods of fair review, informant anonymity, timely payment, and disclosure of tax avoidance with ordinary tax-administration mechanics such as award standards, reporting formats, and deduction rules. Nothing in the summary directly advances moral harm or directly restrains a named evil. Its protections concern whistleblowers reporting private tax avoidance, not government wrongdoing or abuse. The existing good polarity rests on tags that the summary does not clearly support.
Theological note: The bill concerns the fair administration of tax law and the treatment of private persons who report tax avoidance. Scripture supports truthful reporting and just treatment of those who bring wrongdoing to light, and it also requires honest dealing in public and commercial life. The measure's main issues are procedural fairness, protection of informants, and the orderly administration of awards. These are prudential questions of governance and do not on their face involve direct moral evil.

## Recorded votes

Roll 138: On Motion to Suspend the Rules and Pass, as Amended. Yea 346 · Nay 10 · Other 73.

HTML: https://justmeasure.org/bill/hr-7959-119/
