Cooper v. Comm'r
United States Tax Court
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
- Naftel v. CommissionerUnited States Tax Court · 1985
- Craig v. Comm'rUnited States Tax Court · 2002
- Pyo v. CommissionerUnited States Tax Court · 1984
- Offiler v. CommissionerUnited States Tax Court · 2000
- Kluger v. CommissionerUnited States Tax Court · 1984
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