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.

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