Procedural Issues
Tax Opinions

Doyle v. Commissioner
T.C. Memo. 2020-139

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Doyle v. Commissioner (T.C. Memo. 2020-139). The issue before the court in Doyle v. Commissionerwas whether the IRS’s Whistleblower Office abused its discretion in issuing a determination which denied the petitioners’ two whistleblower claims based on the ground that the IRS took no action based on the information that the petitioners provided, even though the Criminal Investigative Division was unclear

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Scott St. Amand October 8, 2020
Procedural Issues
Tax Opinions

Neal v. Commissioner
T.C. Memo. 2020-138

On October 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Neal v. Commissioner (T.C. Memo. 2020-138). The issue before the court in Neal v. Commissioner was whether the IRS Whistleblower Office abused its discretion in failing to foreword the petitioner’s Form 211 to Exam, when the target’s returns were already being audited, and another whistleblower had already whistleblown against the target for the same tax year. Republication of Neal v.

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Scott St. Amand October 5, 2020
Procedural Issues
Tax Opinions

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
Tax Opinions

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
Tax Opinions

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
Tax Opinions

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
Tax Opinions

Belanger v. Commissioner
T.C. Memo. 2020-130

On September 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Belanger v. Commissioner (T.C. Memo. 2020-130). The primary issues before the court in Belanger v. Commissioner were (1) whether the IRS timely mailed a notice of deficiency to the petitioner; (3) whether the petitioner had unreported income; and (3) whether the petitioner was liable for civil fraud penalties. Background to Belanger v. Commissioner The petitioner is French-Canadian, so he can’t

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Scott St. Amand September 10, 2020
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