resulting from the action (including any related ac-
tions) or from any settlement in response to such ac-
tion. The determination of the amount of such 
award by the Whistleblower Office shall depend upon 
the extent to which the individual substantially con-
tributed to such action. 
‘‘(2) AWARD IN CASE OF LESS SUBSTANTIAL 
CONTRIBUTION.— 
‘‘(A) IN GENERAL.—In the event the ac-
tion described in paragraph (1) is one which the 
Whistleblower Office determines to be based 
principally on disclosures of specific allegations 
(other than information provided by the indi-
vidual described in paragraph (1)) resulting 
from a judicial or administrative hearing, from 
a governmental report, hearing, audit, or inves-
tigation, or from the news media, the Whistle-
blower Office may award such sums as it con-
siders appropriate, but in no case more than 10 
percent of the collected proceeds (including pen-
alties, interest, additions to tax, and additional 
amounts) resulting from the action (including 
any related actions) or from any settlement in 
response to such action, taking into account the 
significance of the individual’s information and 
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the role of such individual and any legal rep-
resentative of such individual in contributing to 
such action. 
‘‘(B) NONAPPLICATION
OF
PARAGRAPH 
WHERE INDIVIDUAL IS ORIGINAL SOURCE OF 
INFORMATION.—Subparagraph (A) shall not 
apply if the information resulting in the initi-
ation of the action described in paragraph (1) 
was originally provided by the individual de-
scribed in paragraph (1). 
‘‘(3) REDUCTION IN OR DENIAL OF AWARD.— 
If the Whistleblower Office determines that the 
claim for an award under paragraph (1) or (2) is 
brought by an individual who planned and initiated 
the actions that led to the underpayment of tax or 
actions described in subsection (a)(2), then the 
Whistleblower Office may appropriately reduce such 
award. If such individual is convicted of criminal 
conduct arising from the role described in the pre-
ceding sentence, the Whistleblower Office shall deny 
any award. 
‘‘(4) APPEAL
OF
AWARD
DETERMINATION.— 
Any determination regarding an award under para-
graph (1), (2), or (3) may, within 30 days of such 
determination, be appealed to the Tax Court (and 
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the Tax Court shall have jurisdiction with respect to 
such matter). 
‘‘(5) APPLICATION OF THIS SUBSECTION.—This 
subsection shall apply with respect to any action— 
‘‘(A) against any taxpayer, but in the case 
of any individual, only if such individual’s gross 
income exceeds $200,000 for any taxable year 
subject to such action, and 
‘‘(B) if the tax, penalties, interest, addi-
tions to tax, and additional amounts in dispute 
exceed $2,000,000. 
‘‘(6) ADDITIONAL RULES.— 
‘‘(A) NO CONTRACT NECESSARY.—No con-
tract with the Internal Revenue Service is nec-
essary for any individual to receive an award 
under this subsection. 
‘‘(B) REPRESENTATION.—Any individual 
described in paragraph (1) or (2) may be rep-
resented by counsel. 
‘‘(C) SUBMISSION OF INFORMATION.—No 
award may be made under this subsection 
based on information submitted to the Sec-
retary unless such information is submitted 
under penalty of perjury.’’. 
(2) ASSIGNMENT TO SPECIAL TRIAL JUDGES.— 
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(A) IN GENERAL.—Section 7443A(b) (re-
lating to proceedings which may be assigned to 
special trial judges) is amended by striking 
‘‘and’’ at the end of paragraph (4), by redesig-
nating paragraph (5) as paragraph (6), and by 
inserting after paragraph (4) the following new 
paragraph: 
‘‘(5) any proceeding under section 7623(b)(4), 
and’’. 
(B) CONFORMING
AMENDMENT.—Section 
7443A(c) is amended by striking ‘‘or (4)’’ and 
inserting ‘‘(4), or (5)’’. 
(3) DEDUCTION ALLOWED WHETHER OR NOT 
TAXPAYER ITEMIZES.—Subsection (a) of section 62 
(relating to general rule defining adjusted gross in-
come) is amended by inserting after paragraph (20) 
the following new paragraph: 
‘‘(21) ATTORNEYS FEES RELATING TO AWARDS 
TO
WHISTLEBLOWERS.—Any deduction allowable 
under this chapter for attorney fees and court costs 
paid by, or on behalf of, the taxpayer in connection 
with any award under section 7623(b) (relating to 
awards to whistleblowers). The preceding sentence 
shall not apply to any deduction in excess of the 
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