Procedural Issues
Abuse of Discretion

Frantz v. Commissioner
T.C. Memo. 2020-64

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Frantz v. Commissioner (T.C. Memo. 2020-64). The issue before the court in Frantz v. Commissioner was whether the IRS Whistleblower Office abused its discretion to investigate a claim against the trustee of the petitioner’s chapter 7 bankruptcy estate, who the petitioner claimed significantly understated the estate’s tax liability. Background to Frantz v. Commissioner The petitioner was a potato farmer, or

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Scott St. Amand May 19, 2020
Procedural Issues
Abuse of Discretion

Kansky v. Commissioner
T.C. Memo. 2020-43

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kansky v. Commissioner (T.C. Memo. 2020-43). The issue properly before the court in Kansky v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in rejecting the petitioner’s claim on the basis that it was speculative and did not provide specific or credible information regarding a violation of the Federal tax laws. Background to the Claim in

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Scott St. Amand April 13, 2020
Procedural Issues
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 v. Commissioner 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. Background to Lewis v. Commissioner The moral of the story

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Scott St. Amand April 8, 2020
Procedural Issues
Abuse of Discretion

Cline v. Commissioner
T.C. Memo. 2020-35

On March 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Cline v. Commissioner (T.C. Memo. 2020-34). The issue presented in Cline v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion when it denied the petitioners claims against a taxpayer because such claims failed to provide specific and credible information regarding tax underpayments or violations of internal revenue laws. Background to Cline v. Commissioner The petitioner alleged that

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Scott St. Amand March 16, 2020
Procedural Issues
Abuse of Discretion

Pulcine v. Commissioner (T.C. Memo. 2020-29)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Pulcine v. Commissioner (T.C. Memo. 2020-29). The primary issue presented in Pulcine was whether a whistleblower, whose report initiated an audit of the alleged bad actor, which ultimately resulted in the “bad actor” receiving a refund on his return, demonstrated that the IRS’s Whistleblower Office (WBO) abused its discretion in not awarding the whistleblower for his information.

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Scott St. Amand March 2, 2020
Procedural Issues
Abuse of Discretion

Alber v. Commissioner
T.C. Memo. 2020-20

On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the information provided to support such claim was speculative and/or did not provide specific or credible information regarding tax underpayments or violations of internal revenue laws.

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Scott St. Amand January 30, 2020
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Frantz v. Commissioner
T.C. Memo. 2020-64

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Frantz v. Commissioner (T.C. Memo. 2020-64). The issue before the court in Frantz v. Commissioner was whether the IRS Whistleblower Office abused its discretion to investigate a claim against the trustee of the petitioner’s chapter

Read More »
Scott St. Amand May 19, 2020

Kansky v. Commissioner
T.C. Memo. 2020-43

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kansky v. Commissioner (T.C. Memo. 2020-43). The issue properly before the court in Kansky v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in rejecting the petitioner’s claim on the basis

Read More »
Scott St. Amand April 13, 2020

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 v. Commissioner 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

Read More »
Scott St. Amand April 8, 2020

Cline v. Commissioner
T.C. Memo. 2020-35

On March 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Cline v. Commissioner (T.C. Memo. 2020-34). The issue presented in Cline v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion when it denied the petitioners claims against a taxpayer because such claims

Read More »
Scott St. Amand March 16, 2020

Pulcine v. Commissioner (T.C. Memo. 2020-29)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Pulcine v. Commissioner (T.C. Memo. 2020-29). The primary issue presented in Pulcine was whether a whistleblower, whose report initiated an audit of the alleged bad actor, which ultimately resulted in the “bad actor” receiving a

Read More »
Scott St. Amand March 2, 2020

Alber v. Commissioner
T.C. Memo. 2020-20

On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the

Read More »
Scott St. Amand January 30, 2020