Ringo v. Commissioner
United States Tax Court
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
- Grupo Dataflux v. Atlas Global Group, L. P.Supreme Court of the United States · 2004
- Naftel v. CommissionerUnited States Tax Court · 1985
- Mollan v. TorranceSupreme Court of the United States · 1824
- Smith v. SperlingSupreme Court of the United States · 1957
- Breman v. CommissionerUnited States Tax Court · 1976
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