Determination of Whistleblower Award

Peterfreund v. Commissioner (T.C. Memo. 2021-83)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did not collect any proceeds from the target taxpayer on the basis of the information the petitioner furnished. Whistleblowin’ Jurisdiction The Tax Court has jurisdiction to

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Determination of Whistleblower Award

Whistleblower 10084-16W v. Commissioner (T.C. Memo. 2021-73)

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 10084-16W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 10084-16W was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background 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 the information by hand to an

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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 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 The petitioner filed 21 Forms 211 (Application for Award for Original Information) with the IRS’s Whistleblower Office (WBO), alleging

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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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Abuse of Discretion

Van Bemmelen v. Commissioner (155 T.C. No. 4)

On August 27, 2020, the Tax Court issued its opinion in Van Bemmelen v. Commissioner, 155 T.C. No. 4. The primary issue presented in Van Bemmelen was whether the administrative record could be supplemented with evidence not considered by the IRS’s Whistleblower Office when it rejected the petitioner’s claim. Background In 2018, the petitioner submitted a Form 211 to the IRS’s Whistleblower Office (WBO). In this claim, the petitioner references an October 2012 submission regarding

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Abuse of Discretion

Whistleblower 21276-13W v. Commissioner (155 T.C. No. 2)

On August 26, 2020, the Tax Court issued its opinion in Whistleblower 21276-13W v. Commissioner, 155 T.C. No. 2. The primary issue presented in Whistleblower 21276-13W was whether the Tax Court had jurisdiction to hear and determine a whistleblower-related issue rather than remand it to the IRS Whistleblower Office when remand would have been futile because there was only one possible disposition, as a matter of law, and such matter was before the court. The

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Abuse of Discretion

Lewis v. Commissioner (154 T.C. No. 8)

On April 8, 2020, the Tax Court issued its opinion in Lewis v. Commissioner, 154 T.C. No. 8. The issue presented in Lewis was whether the IRS abused its discretion in the computation of his award by excluding reported, paid tax from the collected proceeds and by determining that there was no possibility of future proceeds relating to the deceased target taxpayer’s estate. Whistleblower Awards – Tax Court’s Authority to Review Mandatory Awards The moral

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Peterfreund v. Commissioner (T.C. Memo. 2021-83)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did

Read More »

Whistleblower 10084-16W v. Commissioner (T.C. Memo. 2021-73)

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 10084-16W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 10084-16W was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background In June 2010, the petitioner

Read More »

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 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 §

Read More »

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 »

Van Bemmelen v. Commissioner (155 T.C. No. 4)

On August 27, 2020, the Tax Court issued its opinion in Van Bemmelen v. Commissioner, 155 T.C. No. 4. The primary issue presented in Van Bemmelen was whether the administrative record could be supplemented with evidence not considered by the IRS’s Whistleblower Office when it rejected the petitioner’s claim. Background

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Whistleblower 21276-13W v. Commissioner (155 T.C. No. 2)

On August 26, 2020, the Tax Court issued its opinion in Whistleblower 21276-13W v. Commissioner, 155 T.C. No. 2. The primary issue presented in Whistleblower 21276-13W was whether the Tax Court had jurisdiction to hear and determine a whistleblower-related issue rather than remand it to the IRS Whistleblower Office when

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Lewis v. Commissioner (154 T.C. No. 8)

On April 8, 2020, the Tax Court issued its opinion in Lewis v. Commissioner, 154 T.C. No. 8. The issue presented in Lewis was whether the IRS abused its discretion in the computation of his award by excluding reported, paid tax from the collected proceeds and by determining that there

Read More »