Legal Opinion

Ringo v. Commissioner

United States Tax Court

Decided October 6, 2014No. Docket No. 29562-12WPublishedCited by 4 opinions

P filed with R's Whistleblower Office (W) an application for a whistleblower award under I.R.C. sec. 7623. On Nov. 7, 2012, W mailed to P a letter stating that P was ineligible for such an award because P did not provide R with information that resulted in the collection of any tax from the target. P timely filed a petition with this Court.

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P filed with R's Whistleblower Office (W) an application for a whistleblower award under I.R.C. sec. 7623. On Nov. 7, 2012, W mailed to P a letter stating that P was ineligible for such an award because P did not provide R with information that resulted in the collection of any tax from the target. P timely filed a petition with this Court. I.R.C. sec. 7623(b)(4) provides that "[a]ny determination regarding an award under paragraph (1), (2), or (3) [of I.R.C. sec. 7623(b)] may, within 30 days of such determination, be appealed to the Tax Court (and the Tax Court shall have jurisdiction with…

1Opinion of the Court

OPINION

Colvin, Judge:

The Internal Revenue Service (IRS) Whistleblower Office mailed to petitioner a letter on November 7, 2012, stating that he was ineligible for a whistleblower award under section 7623. Petitioner commenced this whistleblower proceeding by timely filing a petition pursuant to section 7623(b)(4). Respondent moves to dismiss the case for lack of jurisdiction. As discussed below, we will deny respondent’s motion.

Neither party requested a hearing, and we conclude that none is necessary to decide respondent’s motion to dismiss. The following undisputed information appears in the…

2Cases cited15 opinions

  1. Grupo Dataflux v. Atlas Global Group, L. P.Supreme Court of the United States · 2004
  2. Naftel v. CommissionerUnited States Tax Court · 1985
  3. Mollan v. TorranceSupreme Court of the United States · 1824
  4. Smith v. SperlingSupreme Court of the United States · 1957
  5. Breman v. CommissionerUnited States Tax Court · 1976

10 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Kasper v. Comm'rUnited States Tax Court · 2017
  2. Mica Ringo v. CommissionerUnited States Tax Court · 2014
  3. Whistleblower 21276-13W v. CommissionerUnited States Tax Court · 2020
  4. Whistleblower 4496-15W v. Comm'rUnited States Tax Court · 2017

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