On September 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Chow v. Commissioner (T.C. Memo. 2021-106). The primary issue presented in Chow v. Commissioner was whether the IRS’s Whistleblower Office (WBO) abused its discretion when it denied the petitioners’ claim on the basis that the information that they provided was bullshit (rather, “not credible”). Held: No. You people are crazy. Background to Chow v. Commissioner Mr. and Mrs. Wai-Cheung Wilson Chow rented a home in California from an individual (target taxpayer or target). The Chows claim that the target boasted about owning several other rental properties that she rented to tenants on a cash-only basis to avoid paying taxes on the income. In April 2018, after moving out of the target’s property, the Chows filed Form 211 (Application for Award for Original Information) with the IRS. On the Form 211, the Chows alleged that the target…