On September 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Neal v. Commissioner (T.C. Memo. 2020-135). The issues before the court in Neal v. Commissioner were whether the IRS’s Whistleblower Office abused its discretion when it determined (a) that the petitioner’s claim should not be forwarded to Exam; (b) that the information provided did not result in the collection of any proceeds; and (c) as such, the petitioner was not entitled to a whistleblower award. Background to Neal v. Commissioner The petitioner worked for corporation, which petitioner claimed took several inappropriate write-downs on its debt portfolios. The petitioner filed a Form 211 in May 2014, but he omitted certain important information. Unfortunately for the petitioner, someone had beat him to the punch and previously filed a Form 211 alleging tax issues concerning the target corporation. The IRS denied the petitioner’s claim because the issue had…