Tax Court retains jurisdiction while Whistleblower Office issues revised determination, denies IRS Motion for Remand.

by | Aug 4, 2017 | Administration of Whistleblower Claims, Award Determinations, IRS Whistleblower Office, Judicial Review

On July 28, 2017, the Tax Court denied the April 14, 2016 Joint Motion to Remand the case to the IRS Whistleblower Office.  In the joint motion, the parties represented that the IRS Whistleblower Office had reconsidered its determination.  The Tax Court...

U.S. Tax Court: The section 7623(b)(5)(B) phrase “amounts in dispute” is not specifically limited to only those amounts directly or indirectly attributable to the whistleblower information.

by | Jun 13, 2017 | Award Determinations, Guidance, Judicial Review, Whistleblower Awards

The United States Tax Court held in Smith v. Commissioner of Internal Revenue that the threshold limitation found in section 7623(b)(5) have “clear meaning” and were intended to limit the nondiscretionary award regime to larger cases.  The Court...
Lynam Knott