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…
1Opinion of the Court
OPINION
Colvin, Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. For reasons discussed below we will deny respondent’s motion.
Petitioners commenced this whistleblower proceeding pursuant to section 7623(b)(4).1 Respondent then moved to dismiss for lack of jurisdiction, and petitioners filed an objection to respondent’s motion. Neither party requested a hearing, and we conclude that none is necessary to decide respondent’s motion.
For purposes of deciding respondent’s motion, we consider the following undisputed information contained in the…
2Cases cited11 opinions
- Utility Air Regulatory Group v. EPASupreme Court of the United States · 2014
- Craig v. Comm'rUnited States Tax Court · 2002
- Breman v. CommissionerUnited States Tax Court · 1976
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Cooper v. Comm'rUnited States Tax Court · 2010
6 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Thomas M. Comparini & Vicki Comparini v. CommissionerUnited States Tax Court · 2014
- Whistleblower 26876-15W v. Comm'rUnited States Tax Court · 2016
- Cindy Damiani v. CommissionerUnited States Tax Court · 2020
- Comparini v. Comm'rUnited States Tax Court · 2014
- Felix Ewald Friedel v. CommissionerUnited States Tax Court · 2020
4 more not listed; retrieve them via the Exa API.