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Title 26, Internal Revenue Code section 7623(b) sets forth the rules attendant to the IRSwhistleblower program, including the provision for awards ranging between 15% and30% of proceeds collected by the IRS as a result of information provided. 30 Awardsrequire that the unpaid tax amounts identified and reported by the whistleblower exceed$2 million (inclusive of taxes, penalties, and interest). 31In fiscal year 2013, the last year for which information about the IRS program isavailable, 32the IRS reported paying $53 million to 122 whistleblowers in 2013, amarked decrease from the $125 million paid out to 128 whistleblowers in 2012. TheIRS program has been dogged by slow evaluation and processing of whistleblowerclaims, with over 3000 claims reported as remaining open from 2012, and significantnumbers of open claims remaining from years dating back to 2007. 33The single largest and important whistleblower award to date was the $104 million paidin 2012 to Bradley Birkenfeld, a former UBS bank executive convicted in 2009 for hisrole in the tax evasion scheme that he reported. 34 Birkenfeld provided information onUBS’s assistance to U.S. taxpayers with undeclared accounts held overseas and hasbeen credited for driving a 2009 settlement between the DOJ and UBS which imposednearly $8oo million in penalties and required the disclosure of account information forthousands of U.S. clients of UBS.30 I.R.C. § 7623(b) (2006), http://www.irs.gov/uac/Internal-Revenue-Code-(IRC)-7623(b).31 Id.32 IRS Fiscal Year 2013 Report to the Congress on the Use of Section 7623, (Apr. 10, 2013), available athttp://www.irs.gov/pub/whistleblower/Whistleblower_Annual_report_FY_13_3_7_14_52549.pdf.33 Id.34 David Kocieniewski, Whistle-Blower Awarded $104 Million by I.R.S., N.Y. Times, Sept. 11, 2012,http://www.nytimes.com/2012/09/12/business/whistle-blower-awarded-104-million-by-irs.html?_r=0.12