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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 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.


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 friends (who, interestingly, were so eager to stab him that many missed and stabbed their co-conspirators).  Kai su, teknon?*

Author’s note:  Caesar did not say, “Et tu, Brute?” as Shakespeare would have you believe.  He actually exclaimed in Greek “Kai su, teknon?” This means, “and you, my son,” which confirmed a long-standing rumor that Marcus Junius Brutus, the leader of the plot to kill Caesar, was actually Caesar’s illegitimate son.

In the present case, the petitioner would have done well to make haste a skosh more quickly, as he was beaten out by an earlier whistleblower, and the IRS did not credit him for information that they already possessed regarding the target.

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

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