Kostelanetz attorneys Usman Mohammad, Caroline Rule, and Bryan C. Skarlatos were mentioned in a Law360 article titled “DC Circuit Hands Banker’s Estate Win In IRS Whistleblower Bid” regarding the firm’s work representing the estate of Joseph Insinga.
“The decision is a win for both whistleblowers and ultimately the IRS’s whistleblower program,” Usman told Law360, “because it shows that the courts will review award decisions and require the IRS to apply the whistleblower rules correctly, which can only increase confidence in the program.”
The late Joseph A. Insinga, a Dutch bank executive, was a whistleblower who alerted the IRS to two companies’ participation in a complex tax avoidance scheme with his employer. Despite eight taxpayers being implicated in the ensuing investigation, the IRS Whistleblower Office in 2013 denied Insinga’s award, and that decision was upheld by the U.S. Tax Court a decade later in 2023 after Insinga died.
On August 8, 2025, the D.C. Circuit reversed the U.S. Tax Court’s decision and sided with Insinga’s estate that the IRS used the wrong legal standard to deny his whistleblower award. U.S. Circuit Judge Patricia Millett also held that the IRS wrongly refused to supplement the investigations’ administrative record with materials favoring Insinga.
You can learn more about the Insinga estate’s successful appeal by reading the complete article here.
About Caroline
Caroline’s practice focuses on civil and criminal tax matters and complex civil litigation. She also advises accounting firms about best practices when outsourcing work offshore, including compliance with confidentiality requirements of the Internal Revenue Code, the Gramm-Leach-Bliley Act, and the FTC Safeguards Rule.
About Bryan
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.
About Usman
Usman’s tax controversy practice includes defending clients in federal and state criminal matters involving issues such as tax shelters, payroll tax, check cashing, structuring cash deposits, filing false returns, and failing to file tax returns. He also has extensive experience with government procurement award protests, Article 78 proceedings involving procurement matters, foreign asset reporting issues, IRS responsible person and trust fund recovery penalty matters, IRS whistleblower matters, and IRS collection cases.
