Legal Opinion

Whistleblower 11099-13W v. Comm'r

United States Tax Court

Decided July 28, 2016No. Docket No. 11099-13WPublished

Whistleblower petitioned for review of the IRS' decision not to make an award to him for information that purportedly led to the collection of unpaid taxes and other amounts. He moved to compel production of documents. R objects principally on grounds of relevance. Held: R's claim of lack of relevance presents an unsettled question of law as to when the IRS proceeds on the basis of information provided by a whistleblower.

Read the full summary

Whistleblower petitioned for review of the IRS' decision not to make an award to him for information that purportedly led to the collection of unpaid taxes and other amounts. He moved to compel production of documents. R objects principally on grounds of relevance. Held: R's claim of lack of relevance presents an unsettled question of law as to when the IRS proceeds on the basis of information provided by a whistleblower. SeeI.R.C. sec. 7623(b)(1); sec. 301.7623-2(b), Proced. & Admin. Regs. Held, further, the Court will not in the context of this discovery dispute decide a question of law; if…

1Opinion of the Court

WHISTLEBLOWER 11099-13W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Whistleblower 11099-13W v. Comm'r

Docket No. 11099-13W.

United States Tax Court

147 T.C. 110; 2016 U.S. Tax Ct. LEXIS 19; 147 T.C. No. 3;

July 28, 2016, Filed

Whistleblower petitioned for review of the IRS' decision not to make an award to him for information that purportedly led to the collection of unpaid taxes and other amounts. He moved to compel production of documents. R objects principally on grounds of relevance.

Held: R's claim of lack of relevance presents an unsettled question of law as to when the IRS…

2Cases cited3 opinions

  1. ['Cartagena v. Centerpoint Nine, Inc.']District Court, District of Columbia · 2014
  2. Whistleblower One v. Comm'rUnited States Tax Court · 2015
  3. Dynamo Holdings Ltd. Partnership v. CommissionerUnited States Tax Court · 2014

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API