Procedural Issues
Abuse of Discretion

Stevenson v. Commissioner
T.C. Memo. 2020-137

On September 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevenson v. Commissioner (T.C. Memo. 2020-137). The issue before the court in Stevenson v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting the petitioner’s claim on the ground that he did not provide information regarding any Federal tax violation. Background to Stevenson v. Commissioner Although there are some pro se petitioners who have surprised me with

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Scott St. Amand September 30, 2020
Procedural Issues
Abuse of Discretion

Neal v. Commissioner
T.C. Memo. 2020-135

On September 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Neal v. Commissioner (T.C. Memo. 2020-135). The issues before the court in Neal v. Commissioner were whether the IRS’s Whistleblower Office abused its discretion when it determined (a) that the petitioner’s claim should not be forwarded to Exam; (b) that the information provided did not result in the collection of any proceeds; and (c) as such, the petitioner was not

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Scott St. Amand September 28, 2020
Procedural Issues
Crazy Germans

Damiani v. Commissioner
T.C. Memo. 2020-132

On September 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Damiani v. Commissioner (T.C. Memo. 2020-132). The primary issue before the court in Damiani v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting the petitioner’s claim on the ground that she did not provide any information whatsoever regarding a federal tax violation. The Crazy Rears its Head Again in Damiani v. Commissioner Not to be done by

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Scott St. Amand September 17, 2020
Procedural Issues
Crazy Germans

Friedel v. Commissioner
T.C. Memo. 2020-131

On September 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Friedel v. Commissioner (T.C. Memo. 2020-131). The primary issue before the court in Friedel v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting a German national’s whistleblower claim against six targets, all of whom were officials within the German government on the basis that they had committed (inter alia) fiduciary fraud, breach of trust, bond fraud,

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Scott St. Amand September 17, 2020
Procedural Issues
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 v. Commissioner 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 to Van Bemmelen v. Commissioner In 2018, the petitioner submitted a Form 211 to the IRS’s Whistleblower Office (WBO). In this claim, the petitioner references

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Scott St. Amand August 27, 2020
Procedural Issues
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 v. Commissioner 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.

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Scott St. Amand August 26, 2020
Procedural Issues
Abuse of Discretion

Waszczuk v. Commissioner
T.C. Memo. 2020-75

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Waszczuk v. Commissioner (T.C. Memo. 2020-75). The issue before the court in Waszczuk v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion by rejecting the petitioner’s whistleblower claim (which the WBO treated as two claims, when in reality it was one claim with an amendment by subsequent letter, which letter the WBO treated as a separate, but

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Scott St. Amand June 4, 2020
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Stevenson v. Commissioner
T.C. Memo. 2020-137

On September 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevenson v. Commissioner (T.C. Memo. 2020-137). The issue before the court in Stevenson v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting the petitioner’s claim on the ground that he did

Read More »
Scott St. Amand September 30, 2020

Neal v. Commissioner
T.C. Memo. 2020-135

On September 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Neal v. Commissioner (T.C. Memo. 2020-135). The issues before the court in Neal v. Commissioner were whether the IRS’s Whistleblower Office abused its discretion when it determined (a) that the petitioner’s claim should not be

Read More »
Scott St. Amand September 28, 2020

Damiani v. Commissioner
T.C. Memo. 2020-132

On September 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Damiani v. Commissioner (T.C. Memo. 2020-132). The primary issue before the court in Damiani v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting the petitioner’s claim on the ground that she did

Read More »
Scott St. Amand September 17, 2020

Friedel v. Commissioner
T.C. Memo. 2020-131

On September 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Friedel v. Commissioner (T.C. Memo. 2020-131). The primary issue before the court in Friedel v. Commissioner was whether the IRS Whistleblower Office abused its discretion in rejecting a German national’s whistleblower claim against six targets,

Read More »
Scott St. Amand September 17, 2020

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 v. Commissioner 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

Read More »
Scott St. Amand August 27, 2020

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 v. Commissioner was whether the Tax Court had jurisdiction to hear and determine a whistleblower-related issue rather than remand it to the IRS Whistleblower Office

Read More »
Scott St. Amand August 26, 2020

Waszczuk v. Commissioner
T.C. Memo. 2020-75

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Waszczuk v. Commissioner (T.C. Memo. 2020-75). The issue before the court in Waszczuk v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion by rejecting the petitioner’s whistleblower claim (which the WBO treated

Read More »
Scott St. Amand June 4, 2020