Rogers v. Commissioner (157 T.C. No. 3)

On August 2, 2021, the Tax Court issued its opinion in Rogers v. Commissioner, 157 T.C. No. 3. The primary issue presented in Rogers was whether the IRS Whistleblower Office abused its discretion when it rejected/denied the petitioner’s claim. Held: Oh yeah. Side Note One of the attorneys for the IRS is named Bartholomew Cirenza.  There’s a fair to middling chance that he has been given more swirlies, wedgies, and other sundry childhood punishments than he can (or cares to) remember. Summary and Holding IRC § 7623 provides for awards to individuals (commonly referred to as whistleblowers) who submit information to the Government about third parties who have underpaid their taxes or otherwise violated the internal revenue laws. The IRS Whistleblower Office (WBO) has been entrusted with the responsibility of reviewing claims under IRC § 7623 to determine whether a whistleblower is entitled to an award. The Department of the…

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