Edward A. Morse (Creighton) has posted Whistleblowers and Tax Enforcement: Using Inside Information to Close the "Tax Gap" on SSRN.  Here is the abstract:

This article examines the current legal structure allowing rewards for informants who provide information to assist the IRS in the enforcement of the tax laws. IRS data suggest that informants are a cost-effective means of enhancing tax enforcement. The Tax Relief and Health Care Act of 2006 introduced a separate whistleblower award program that provides even higher rewards (up to 30 percent of the amount collected) and greater certainty in the payment of such rewards, including a process for enforcing reward claims against the government through litigation in the Tax Court. Although the whistleblower provisions may enhance tax enforcement, they also raise significant issues concerning taxpayer privacy and IRS secrecy in the context of lawsuits to enforce reward claims. Moreover, prospects for large financial rewards without comprehensive attention to eligibility constraint may effectively induce prospective whistleblowers to breach other legal or ethical responsibilities. The article argues that these important issues deserve more careful attention from Congress, and should not be relegated to administrative or judicial development.