Legal Opinion

Whistleblower One v. Comm'r

United States Tax Court

Decided September 16, 2015No. Docket No. 10683-13WPublishedCited by 6 opinions

This is a so-called whistleblower case brought pursuant to I.R.C. sec. 7623(b)(4). Ps move to compel production of documents and responses to interrogatories (motions). R objects on the ground that the requested information is outside the administrative record compiled by R's Whistleblower Office and is, thus, not discoverable. 1. Held: Even were we to agree with R that the Court's scope of review is the administrative record, R cannot unilaterally decide what constitutes…

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This is a so-called whistleblower case brought pursuant to I.R.C. sec. 7623(b)(4). Ps move to compel production of documents and responses to interrogatories (motions). R objects on the ground that the requested information is outside the administrative record compiled by R's Whistleblower Office and is, thus, not discoverable. 1. Held: Even were we to agree with R that the Court's scope of review is the administrative record, R cannot unilaterally decide what constitutes that record, and R's response indicates that the purported record is incomplete. 2. Held, further, we will issue an…

1Opinion of the Court

WHISTLEBLOWER ONE 10683-13W, WHISTLEBLOWER TWO 10683-13W, AND WHISTLEBLOWER THREE 10683-13W, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Whistleblower One v. Comm'r

Docket No. 10683-13W.

United States Tax Court

145 T.C. 204; 2015 U.S. Tax Ct. LEXIS 38; 145 T.C. No. 8;

September 16, 2015, Filed

An appropriate order will be issued.

This is a so-called whistleblower case brought pursuant to

I.R.C. sec. 7623(b)(4). Ps move to compel production of documents and responses to interrogatories (motions). R objects on the ground that the requested information is outside the administrative…

2Cases cited6 opinions

  1. Asarco, Inc. v. U. S. Environmental Protection AgencyCourt of Appeals for the Ninth Circuit · 1980
  2. Federal Power Commission v. Transcontinental Gas Pipe Line Corp.Supreme Court of the United States · 1976
  3. Blaine P. Thompson v. United States Department of LaborCourt of Appeals for the Ninth Circuit · 1989
  4. Tenneco Oil Co. v. Department of EnergyDistrict Court, D. Delaware · 1979
  5. Ad Hoc Metals Coalition v. WhitmanDistrict Court, District of Columbia · 2002

1 more not listed; retrieve them via the Exa API.

3Cited by6 opinions

  1. Whistleblower 22716-13W v. Comm'rUnited States Tax Court · 2016
  2. Awad v. Comm'rUnited States Tax Court · 2017
  3. Kenneth William Kasper v. CommissionerUnited States Tax Court · 2018
  4. Whistleblower 11099-13W v. Comm'rUnited States Tax Court · 2016
  5. Whistleblower 14376-16W v. Comm'rUnited States Tax Court · 2017

1 more not listed; retrieve them via the Exa API.

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