On March 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Cline v. Commissioner (T.C. Memo. 2020-34). The issue presented in Cline v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion when it denied the petitioners claims against a taxpayer because such claims failed to provide specific and credible information regarding tax underpayments or violations of internal revenue laws. Background to Cline v. Commissioner The petitioner alleged that his former employer, which the Tax Court notes had been convicted of fraud multiple times, failed to report income, failed to disclose a stock sale, underreported income in other years, and maintained poor accounting practices. Unfortunately, the statute of limitations for assessment had run against the misfeasor, and the IRS Whistleblower Office (WBO) accordingly rejected the petitioner’s claims and did not forward the claim to Exam for possible further action. The WBO sent the petitioner…