Procedural Issues
Determination of Whistleblower Award

Whistleblower 1008416W v. Commissioner
T.C. Memo. 2021-73

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1008416W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 1008416W v. Commissioner was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background to Whistleblower 1008416W v. Commissioner In June 2010, the petitioner provided whistleblower information about the target taxpayer (target) to an attorney with respondent’s Office of Chief Counsel and delivered

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Scott St. Amand June 21, 2021
Procedural Issues
Abuse of Discretion

McCrory v. Commissioner
156 T.C. No. 6

On March 2, 2021, the Tax Court issued its opinion in McCrory v. Commissioner (156 T.C. No. 6). The underlying issue presented in McCrory v. Commissioner was whether the preliminary award recommendation issued by the IRS’s Whistleblower Office under IRC § 7623(a) constitutes a binding “determination” within the meaning of IRC § 7623(b)(4).  Not so much. Procedural Background to McCrory v. Commissioner The petitioner filed 21 Forms 211 (Application for Award for Original Information) with

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Scott St. Amand March 2, 2021
Procedural Issues
Abuse of Discretion

Kennedy v. Commissioner (T.C. Memo. 2021-3)

On January 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kennedy v. Commissioner (T.C. Memo. 2021-3). The issue presented in Kelley was whether the IRS’s whistleblower office abused its discretion in denying the petitioner’s claims. Background The petitioner claimed that three subsidiaries of a taxpayer owed a middling $150m in unpaid excise taxes, penalties, and interest to Uncle Sam.  The IRS Whistleblower Office (WBO) reviewed the claim, and to everyone’s

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Scott St. Amand January 12, 2021
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Whistleblower 1008416W v. Commissioner
T.C. Memo. 2021-73

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1008416W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 1008416W v. Commissioner was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background to Whistleblower 1008416W v.

Read More »
Scott St. Amand June 21, 2021

McCrory v. Commissioner
156 T.C. No. 6

On March 2, 2021, the Tax Court issued its opinion in McCrory v. Commissioner (156 T.C. No. 6). The underlying issue presented in McCrory v. Commissioner was whether the preliminary award recommendation issued by the IRS’s Whistleblower Office under IRC § 7623(a) constitutes a binding “determination” within the meaning of

Read More »
Scott St. Amand March 2, 2021

Kennedy v. Commissioner (T.C. Memo. 2021-3)

On January 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kennedy v. Commissioner (T.C. Memo. 2021-3). The issue presented in Kelley was whether the IRS’s whistleblower office abused its discretion in denying the petitioner’s claims. Background The petitioner claimed that three subsidiaries of a taxpayer

Read More »
Scott St. Amand January 12, 2021