Legal Opinion

Whistleblower 16158-14W v. Comm'r

United States Tax Court

Decided April 17, 2017No. Docket No. 16158-14WPublished

W provided information to the Internal Revenue Service (IRS) regarding T's alleged failure to withhold and pay over taxes for 2006 through 2008. W supplemented the submission to add years 2009 through 2014. The IRS expanded an ongoing examination for 2006 through 2008 to address the withholding issue that W raised, but that examination did not result in collected proceeds. The IRS did not conduct an examination relating to the withholding issue for subsequent years.

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W provided information to the Internal Revenue Service (IRS) regarding T's alleged failure to withhold and pay over taxes for 2006 through 2008. W supplemented the submission to add years 2009 through 2014. The IRS expanded an ongoing examination for 2006 through 2008 to address the withholding issue that W raised, but that examination did not result in collected proceeds. The IRS did not conduct an examination relating to the withholding issue for subsequent years. T updated its recordkeeping system after 2008. W alleges that improvements to T's recordkeeping resulted in collected proceeds…

1Opinion of the Court

WHISTLEBLOWER 16158-14W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Whistleblower 16158-14W v. Comm'r

Docket No. 16158-14W.

United States Tax Court

2017 U.S. Tax Ct. LEXIS 13; 148 T.C. No. 12;

April 17, 2017, Filed

An appropriate order and decision will be entered.

W provided information to the Internal Revenue Service (IRS) regarding T's alleged failure to withhold and pay over taxes for 2006 through 2008. W supplemented the submission to add years 2009 through 2014. The IRS expanded an ongoing examination for 2006 through 2008 to address the withholding issue that W raised, but…

2Cases cited13 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. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  4. Dahlstrom v. CommissionerUnited States Tax Court · 1985
  5. Shiosaki v. CommissionerUnited States Tax Court · 1974

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