Cooper v. Comm'r
United States Tax Court
P filed two claims for a whistleblower award with R under sec. 7623(b)(4), I.R.C., and R sent a letter to P denying the claims because an award determination could not be made under sec. 7623(b), I.R.C. We earlier denied R's motion to dismiss for lack of jurisdiction, holding that R's letter was a determination conferring jurisdiction on this Court.
Read the full summary
P filed two claims for a whistleblower award with R under sec. 7623(b)(4), I.R.C., and R sent a letter to P denying the claims because an award determination could not be made under sec. 7623(b), I.R.C. We earlier denied R's motion to dismiss for lack of jurisdiction, holding that R's letter was a determination conferring jurisdiction on this Court. Cooper v. Commissioner, 135 T.C. 70 (2010). R subsequently filed an answer to each petition P filed seeking review of R's denial of the whistleblower claims. R attached a memorandum summarizing the facts, legal analysis and legal conclusion for…
1Opinion of the Court
OPINION
Kroupa, Judge:
These cases are before the Court on respondent’s motions for summary judgment filed pursuant to Rule 121.1 Respondent contends that he is entitled to summary judgment as a matter of law because petitioner has not met the threshold requirements for a whistleblower award under section 7623(b). We shall grant respondent’s motions.
Background
The following information is stated for purpose of resolving the pending motions. At the time of filing the petitions, petitioner resided in Nashville, Tennessee.
Petitioner, an attorney, submitted two Forms 211, Application for Award for…
2Cases cited5 opinions
- Associated Press v. United StatesSupreme Court of the United States · 1945
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Cooper v. Comm'rUnited States Tax Court · 2010
3Cited by30 opinions
- Cohen v. CommissionerUnited States Tax Court · 2012
- Whistleblower 14106-10W v. CommissionerUnited States Tax Court · 2011
- Whistleblower 22716-13W v. Comm'rUnited States Tax Court · 2016
- Gonzalez v. Comm'rUnited States Tax Court · 2017
- Meidinger v. CommissionerCourt of Appeals for the D.C. Circuit · 2014
25 more not listed; retrieve them via the Exa API.