Procedural Issues
IRC § 7623

Whistleblower 15977-18W v. Commissioner
T.C. Memo. 2021-143

On December 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 15977-18W v. Commissioner (T.C. Memo. 2021-143). The primary issue presented in Whistleblower 15977-18W was whether the IRS’s Whistleblower Office (WBO) abused its discretion in concluding that the whistleblower claim did not provide specific and credible information sufficient to establish that the target taxpayer was citizen of United States at birth. Held: Discretion sound—no abuse here. Background In early September

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Procedural Issues
Futility

Marino v. Commissioner
T.C. Memo. 2021-130

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

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Procedural Issues
Determination of Whistleblower Award

Insinga v. Commissioner
157 T.C. No. 8

On October 27, 2021, the Tax Court issued its opinion in Insinga v. Commissioner (157 T.C. No. 8). The primary issue presented in Insinga v. Commissioner was whether the Tax Court’s jurisdiction over a whistleblower petition filed under IRC § 7623(b)(4) was extinguished by the death of the petitioner-whistleblower. Held: Heck no; whistle on whistler. Background to Insinga v. Commissioner Pursuant to IRC § 7623(b)(4), the petitioner filed a timely petition in the Tax Court

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Procedural Issues
Abuse of Discretion

McCrory v. Commissioner
T.C. Memo. 2021-116

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory v. Commissioner was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. Background to Whistleblower Claims in McCrory v. Commissioner The petitioner submitted six Forms 211

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Procedural Issues
Anonymity in Whistleblower Complaints

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

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Procedural Issues
Determination of Whistleblower Award

Chow v. Commissioner
T.C. Memo. 2021-106

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

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Procedural Issues
Abuse of Discretion

Rogers v. Commissioner
157 T.C. No. 3

On August 2, 2021, the Tax Court issued its opinion in Rogers v. Commissioner (157 T.C. No. 3). The primary issue presented in Rogers v. Commissioner was whether the IRS Whistleblower Office abused its discretion when it rejected/denied the petitioner’s claim. Held: Oh yeah. Side Note One of the attorneys for the IRS is named Bartholomew Cirenza. There’s a fair to middling chance that he has been given more swirlies, wedgies, and other sundry childhood punishments

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Whistleblower 15977-18W v. Commissioner
T.C. Memo. 2021-143

On December 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 15977-18W v. Commissioner (T.C. Memo. 2021-143). The primary issue presented in Whistleblower 15977-18W was whether the IRS’s Whistleblower Office (WBO) abused its discretion in concluding that the whistleblower claim did not provide specific and

Read More »

Marino v. Commissioner
T.C. Memo. 2021-130

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,

Read More »

Insinga v. Commissioner
157 T.C. No. 8

On October 27, 2021, the Tax Court issued its opinion in Insinga v. Commissioner (157 T.C. No. 8). The primary issue presented in Insinga v. Commissioner was whether the Tax Court’s jurisdiction over a whistleblower petition filed under IRC § 7623(b)(4) was extinguished by the death of the petitioner-whistleblower. Held:

Read More »

McCrory v. Commissioner
T.C. Memo. 2021-116

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory v. Commissioner was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious,

Read More »

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.

Read More »

Chow v. Commissioner
T.C. Memo. 2021-106

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

Read More »

Rogers v. Commissioner
157 T.C. No. 3

On August 2, 2021, the Tax Court issued its opinion in Rogers v. Commissioner (157 T.C. No. 3). The primary issue presented in Rogers v. Commissioner was whether the IRS Whistleblower Office abused its discretion when it rejected/denied the petitioner’s claim. Held: Oh yeah. Side Note One of the attorneys for

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