Awad v. Comm'r
United States Tax Court
P provided information to the IRS Whistleblower Office (WO) regarding individuals TH and TW's alleged failure to disclose their ownership interests in foreign bank accounts. WO forwarded P's information to the Large Business & International Division (LB&I), which declined to examine TH and TW's returns. TH died while LB&I was considering P's information.
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P provided information to the IRS Whistleblower Office (WO) regarding individuals TH and TW's alleged failure to disclose their ownership interests in foreign bank accounts. WO forwarded P's information to the Large Business & International Division (LB&I), which declined to examine TH and TW's returns. TH died while LB&I was considering P's information. Thereafter TW and her adult children filed voluntary disclosures with the Criminal Investigation Division (CID) in which they reported income from a previously undisclosed account at the same foreign bank P had identified. CID accepted the…
1Opinion of the Court
JAMES AWAD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Awad v. Comm'r
Docket No. 3755-14W.
United States Tax Court
T.C. Memo 2017-108; 2017 Tax Ct. Memo LEXIS 104;
June 8, 2017, Filed
Decision will be entered for respondent.
P provided information to the IRS Whistleblower Office (WO) regarding individuals TH and TW's alleged failure to disclose their ownership interests in foreign bank accounts. WO forwarded P's information to the Large Business & International Division (LB&I), which declined to examine TH and TW's returns. TH died while LB&I was considering P's information.…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. CaceresSupreme Court of the United States · 1979
- Charles G. Fargo Elizabeth A. Fargo v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Cooper v. Comm'rUnited States Tax Court · 2010
- Fargo v. Comm'rUnited States Tax Court · 2004
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
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- Whistleblower 14376-16W v. Comm'rUnited States Tax Court · 2017
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