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When former UBS private banker Bradley Birkenfeld asked Stephen Kohn for help in applying to the Internal Revenue Service’s whistle-blower award program in September 2009, he could hardly have been in a deeper legal hole. A month before, Birkenfeld had been sentenced to 40 months in prison—10 months more than prosecutors had recommended—after he pled guilty to conspiring to help a client, Igor Olenicoff, evade U.S. taxes.

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