Whistleblower 11332-13W v. Commissioner
United States Tax Court
Whistleblower W reported a tax fraud scheme, involving W's employer and related entities, to the Government. W provided the Government with information regarding the tax fraud scheme from June 2006 through the fall of 2009. W's information formed the basis of the Government's action against the target taxpayers.
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Whistleblower W reported a tax fraud scheme, involving W's employer and related entities, to the Government. W provided the Government with information regarding the tax fraud scheme from June 2006 through the fall of 2009. W's information formed the basis of the Government's action against the target taxpayers. W filed a Form 211, Application for Award for Original Information, in 2008 and submitted to R documentary evidence related to W's involvement in the Government's investigation. W resubmitted Form 211 in 2011 seeking an award under I.R.C. sec. 7623(b). Shortly thereafter, the…
1Opinion of the Court
OPINION
Kroupa, Judge:
This case 1 is before the Court on respondent’s motion to dismiss for lack of jurisdiction. We decide for the first time whether the Court has jurisdiction to review respondent’s whistleblower claim award determinations where the whistleblower provided information both before and after the enactment of the Tax Relief and Health Care Act of 2006 (TRHCA), 2 Pub. L. No. 109-432, div. A, sec. 406, 120 Stat. at 2958, effective December 20, 2006. We hold that we do. 3
Background
The following background is drawn from the petition and respondent’s motion to dismiss for lack of…
2Cases cited10 opinions
- Scheuer v. RhodesSupreme Court of the United States · 1974
- Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988
- Naftel v. CommissionerUnited States Tax Court · 1985
- Pyo v. CommissionerUnited States Tax Court · 1984
- Kluger v. CommissionerUnited States Tax Court · 1984
5 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Comparini v. Comm'rUnited States Tax Court · 2014
- Whistleblower 22716-13W v. Comm'rUnited States Tax Court · 2016
- Whistleblower 19860-15W v. Comm'rUnited States Tax Court · 2017
- Whistleblower 26876-15W v. Comm'rUnited States Tax Court · 2016
- Kenneth William Kasper v. CommissionerUnited States Tax Court · 2018
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