Neal v. Commissioner
T.C. Memo. 2020-138

On October 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Neal v. Commissioner (T.C. Memo. 2020-138). The issue before the court in Neal v. Commissioner was whether the IRS Whistleblower Office abused its discretion in failing to foreword the petitioner’s Form 211 to Exam, when the target’s returns were already being audited, and another whistleblower had already whistleblown against the target for the same tax year. Republication of Neal v. Commissioner Neal is simply a republication of Neal v. Commissioner, T.C. Memo. 2020-135.  The holdings are identical. Moral of the Story The Roman emperor Augustus was famous for saying “Festina lente,” which means “make haste slowly.”  Though admittedly oxymoronic, Augustus’ made him one of the most successful Roman leader and statesmen in history.  Unlike his adopted father Julius Caesar who made haste with, well, haste, and then was famously stabbed by fifty of his closest…

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