Modifies paragraph (4) of 26 U.S.C. 7623(b) by changing the review standard language and adding that Tax Court review shall be de novo and based on the administrative record plus any newly discovered or previously unavailable evidence.

Strikes reference to "7623(b)" and inserts "7623" in the specified provision of section 62 (as amended by section 62(a)(21)(A)(i)).

Adds a new paragraph (7) to subsection (b) establishing an interest component for whistleblower awards, defining when interest accrues, an exception when notice is provided, and the applicable date for interest calculation.

Amends Section 406(c) of division A of the Tax Relief and Health Care Act of 2006 by modifying paragraph (1) to require the report to include a list and descriptions of the top tax avoidance schemes (not to exceed 10) disclosed by whistleblowers during the year.