Legal Opinion

Cooper v. Comm'r

United States Tax Court

Decided July 8, 2010No. Docket Nos. 24178-09W, 24179-09WPublished

P filed two claims for a whistleblower award with R under sec. 7623(b)(4), I.R.C. R sent a letter to P denying the claims because an award determination could not be made under sec. 7623(b), I.R.C. P subsequently filed petitions in this Court seeking review of R's denial of the whistleblower claims.

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P filed two claims for a whistleblower award with R under sec. 7623(b)(4), I.R.C. R sent a letter to P denying the claims because an award determination could not be made under sec. 7623(b), I.R.C. P subsequently filed petitions in this Court seeking review of R's denial of the whistleblower claims. R filed motions to dismiss these cases for lack of jurisdiction on the ground that no determination notice under sec. 7623(b), I.R.C., was sent to P, to which P objected that the letter R sent was a valid determination notice. Held: R's letter was a determination conferring jurisdiction on this…

1Opinion of the Court

WILLIAM PRENTICE COOPER, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cooper v. Comm'r

Docket Nos. 24178-09W, 24179-09W

United States Tax Court

135 T.C. 70; 2010 U.S. Tax Ct. LEXIS 20; 135 T.C. No. 4;

July 8, 2010, Filed

Appropriate orders will be issued.

P filed two claims for a whistleblower award with R under sec. 7623(b)(4), I.R.C. R sent a letter to P denying the claims because an award determination could not be made under sec. 7623(b), I.R.C. P subsequently filed petitions in this Court seeking review of R's denial of the whistleblower claims.

R filed motions to dismiss…

2Cases cited11 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Craig v. Comm'rUnited States Tax Court · 2002
  3. Pyo v. CommissionerUnited States Tax Court · 1984
  4. Offiler v. CommissionerUnited States Tax Court · 2000
  5. Kluger v. CommissionerUnited States Tax Court · 1984

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