On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the information provided to support such claim was speculative and/or did not provide specific or credible information regarding tax underpayments or violations of internal revenue laws. Background to Alber v. Commissioner The petitioner in Alber was engaged in a lifelong game of Marco Polo with reality, which by all metrics, he was winning handily. The petitioner is a non-U.S. citizen residing in Germany. He submitted a Form 211 (Application for Award for Original Information) to the Whistleblower office of the IRS (WBO) that alleged, and I quote: the “fake Federal Republic of Germany banana republic has been treating [the petitioner] badly…