Whistleblower 1437716W v. Commissioner
T.C. Memo. 2021-113

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1437716W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 1437716W v. Commissioner were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held: Nope on both counts. Background to “Old 77” Whistleblower and Whistleblower 1437716W Peter J. Reilly, a Forbes tax contributor, nicknamed the whistleblower in Whistleblower 1437716W v. Commissioner “Old 77” in an article that came out in August 2019 written after the D.C. Circuit remanded a prior whistleblower case brought by Old 77, telling the Tax Court to keep Old 77’s actual identity off the books.  See Whistleblower 14377-16W v. Commissioner, 148 T.C. 510 (2017), remanded sub nom. In re Sealed Case, 931 F.3d 92 (D.C. Cir. 2019). Reilly observed Whistleblower 14377-16W is my new hero.  Old 77 as I have nicknamed…

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