Legal Opinion

Comparini v. Comm'r

United States Tax Court

Decided October 2, 2014No. Docket No. 6674-13WPublished

Ps filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). In 2012 W mailed four essentially identical letters to Ps stating that Ps are not eligible for an award and inviting Ps to contact W with any questions. Ps later submitted additional information to W in support of Ps' claim.

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Ps filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). In 2012 W mailed four essentially identical letters to Ps stating that Ps are not eligible for an award and inviting Ps to contact W with any questions. Ps later submitted additional information to W in support of Ps' claim. In 2013 W sent a letter (2013 letter) to Ps stating that W "determined your claim still does not meet our criteria for an award", "[o]ur determination remains the same", and "we are closing this claim." Ps petitioned this Court under I.R.C. sec. 7623(b)(4) within 30…

1Opinion of the Court

THOMAS M. COMPARINI AND VICKI COMPARINI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Comparini v. Comm'r

Docket No. 6674-13W

United States Tax Court

143 T.C. 274; 2014 U.S. Tax Ct. LEXIS 47; 143 T.C. No. 14;

October 2, 2014, Filed

An appropriate order denying respondent's motion to dismiss will be issued.

Ps filed with R's Whistleblower Office (W) a claim for a whistleblower award under I.R.C. sec. 7623(b). In 2012 W mailed four essentially identical letters to Ps stating that Ps are not eligible for an award and inviting Ps to contact W with any questions.

Ps later submitted…

2Cases cited16 opinions

  1. Utility Air Regulatory Group v. EPASupreme Court of the United States · 2014
  2. Craig v. Comm'rUnited States Tax Court · 2002
  3. Breman v. CommissionerUnited States Tax Court · 1976
  4. Lunsford v. Comm'rUnited States Tax Court · 2001
  5. Ottawa Silica Company v. The United StatesCourt of Appeals for the Federal Circuit · 1983

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