Whistleblower 14106-10W v. Commissioner
United States Tax Court
P, a former senior executive of X, filed a claim for a whistleblower award under sec. 7623(b), I.R.C., alleging that X had underpaid its taxes. R investigated P's claim but did not open an administrative or judicial proceeding against X and did not collect any additional tax from X on the basis of P's information. R denied P's claim on the basis that an award determination could not be made under sec. 7623(b), I.R.C. P's identity thus far has been kept confidential.
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P, a former senior executive of X, filed a claim for a whistleblower award under sec. 7623(b), I.R.C., alleging that X had underpaid its taxes. R investigated P's claim but did not open an administrative or judicial proceeding against X and did not collect any additional tax from X on the basis of P's information. R denied P's claim on the basis that an award determination could not be made under sec. 7623(b), I.R.C. P's identity thus far has been kept confidential. Asserting that disclosing P's identity in this judicial proceeding would result in retaliation and professional ostracism, P…
1Opinion of the Court
OPINION
Thornton, Judge:
This is an action pursuant to section 7623(b)(4) to review respondent’s denial of petitioner’s claim for a whistleblower award.2 This matter is before the Court on respondent’s motion for summary judgment and petitioner’s motion to seal the record and proceed anonymously.
Background
Petitioner’s Whistleblower Claim
On March 3, 2008, petitioner submitted to the Internal Revenue Service Whistleblower Office (Whistleblower Office) Form 211, Application for Award for Original Information. This submission indicated that while employed as a senior executive in a particular…
2Cases cited69 opinions
- Roe v. WadeSupreme Court of the United States · 1973
- Nixon v. Warner Communications, Inc.Supreme Court of the United States · 1978
- Lugosch v. Pyramid Co. of OnondagaCourt of Appeals for the Second Circuit · 2006
- Roviaro v. United StatesSupreme Court of the United States · 1957
- Richmond Newspapers, Inc. v. VirginiaSupreme Court of the United States · 1980
64 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- In re: Sealed CaseCourt of Appeals for the D.C. Circuit · 2019
- Cohen v. CommissionerUnited States Tax Court · 2012
- Michael Lissack v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2023
- Ringo v. CommissionerUnited States Tax Court · 2014
- Simmons v. CommissionerCourt of Appeals for the D.C. Circuit · 2013
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