On November 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Marino v. Commissioner (T.C. Memo. 2021-130). The primary issue presented in Marino was whether the IRS Whistleblower Office abused its discretion in denying the petitioner an award for information on an alleged ne’er-do-well taxpayer…who, apparently, was dead. Background The petitioner in Marino v. Commissioner filed a Form 211 (Application for Award for Original Information) in 2014, in which he claimed