Comparini v. Comm'r
United States Tax Court
Ps filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). In 2012 W mailed four essentially identical letters to Ps stating that Ps are not eligible for an award and inviting Ps to contact W with any questions. Ps later submitted additional information to W in support of Ps' claim.
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Ps filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). In 2012 W mailed four essentially identical letters to Ps stating that Ps are not eligible for an award and inviting Ps to contact W with any questions. Ps later submitted additional information to W in support of Ps' claim. In 2013 W sent a letter (2013 letter) to Ps stating that W "determined your claim still does not meet our criteria for an award", "[o]ur determination remains the same", and "we are closing this claim." Ps petitioned this Court under I.R.C. sec. 7623(b)(4) within 30…
1Concurrence
Halpern and Lauber, JJ.,
concurring: We agree that the February 2013 letter from the Internal Revenue Service (IRS) Whistleblower Office (Office) embodies a “determination regarding an award” within the meaning of section 7623(b)(4) and that, because petitioners filed a petition within 30 days of that letter, the Court has jurisdiction over this controversy. We therefore concur in the result reached by the opinion of the Court. We write separately because we have concerns about certain portions of the analysis in the opinion and about how it treats our precedents in Friedland v. Commissioner,…
2Cases cited7 opinions
- Ottawa Silica Company v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Cooper v. Comm'rUnited States Tax Court · 2010
- The Charter Company v. United StatesCourt of Appeals for the Eleventh Circuit · 1992
- Ia 80 Group, Inc. And Subsidiaries, Formerly Known as Iowa 80 Truckstop, Inc. And Subsidiaries v. United StatesCourt of Appeals for the Eighth Circuit · 2004
- El Paso Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 2014
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