Legal Opinion

Myers v. Comm'r

United States Tax Court

Decided June 5, 2017No. Docket No. 2181-15WPublished

P filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). W denied P's claim, stating in a letter dated March 13, 2013, that P is not eligible for an award and inviting P to contact W with any further questions. P continued to correspond with W during 2013 and 2014, sometimes submitting additional material regarding his claim. In response, W sent P four separate letters.

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P filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). W denied P's claim, stating in a letter dated March 13, 2013, that P is not eligible for an award and inviting P to contact W with any further questions. P continued to correspond with W during 2013 and 2014, sometimes submitting additional material regarding his claim. In response, W sent P four separate letters. By letters dated November 20, 2013, January 8, 2014, and March 6, 2014, W stated that it had "considered the additional information you provided and determined your claim still…

1Opinion of the Court

DAVID T. MYERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Myers v. Comm'r

Docket No. 2181-15W.

United States Tax Court

2017 U.S. Tax Ct. LEXIS 22; 148 T.C. No. 20;

June 5, 2017, Filed

An order of dismissal for lack of jurisdiction will be entered.

P filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). W denied P's claim, stating in a letter dated March 13, 2013, that P is not eligible for an award and inviting P to contact W with any further questions. P continued to correspond with W during 2013 and 2014, sometimes submitting…

2Cases cited16 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
  3. Breman v. CommissionerUnited States Tax Court · 1976
  4. Mulvania v. CommissionerUnited States Tax Court · 1983
  5. Charles G. Fargo Elizabeth A. Fargo v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006

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