Legal Opinion

Whistleblower 4496-15W v. Comm'r

United States Tax Court

Decided May 25, 2017No. Docket No. 4496-15WPublished

P filed with the IRS Whistleblower Office (Office) Form 211, Application for Award for Original Information, with respect to TP(s). The Office offered P an award that had been reduced by 7.3% on account of the "sequester" imposed by the Budget Control Act of 2011. P accepted this award and, in exchange for prompt payment, waived his judicial appeal rights. The Office subsequently issued P a check in the agreed-upon amount.

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P filed with the IRS Whistleblower Office (Office) Form 211, Application for Award for Original Information, with respect to TP(s). The Office offered P an award that had been reduced by 7.3% on account of the "sequester" imposed by the Budget Control Act of 2011. P accepted this award and, in exchange for prompt payment, waived his judicial appeal rights. The Office subsequently issued P a check in the agreed-upon amount. After cashing the check P filed a petition challenging the 7.3% reduction of his award. R moved to dismiss. 1. Held: The Office's issuance of the check to P constituted its…

1Opinion of the Court

WHISTLEBLOWER 4496-15W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Whistleblower 4496-15W v. Comm'r

Docket No. 4496-15W.

United States Tax Court

2017 U.S. Tax Ct. LEXIS 20; 148 T.C. No. 19; 113 T.C.M. (CCH) 4067;

May 25, 2017, Filed

An order will be entered denying respondent's motion to dismiss for lack of jurisdiction and granting summary judgment for respondent.

P filed with the IRS Whistleblower Office (Office) Form 211, Application for Award for Original Information, with respect to TP(s). The Office offered P an award that had been reduced by 7.3% on account of the "sequester"…

2Cases cited23 opinions

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Callen v. Pennsylvania RailroadSupreme Court of the United States · 1948
  4. Estate of Young v. CommissionerUnited States Tax Court · 1983
  5. Cooper v. Comm'rUnited States Tax Court · 2010

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