Smith v. Comm'r
United States Tax Court
P, a whistleblower, provided information to R. Using P's information, R commenced examinations of a taxpayer that led to the assessment and collection of almost $20 million. R determined that slightly less than $2 million of the collected proceeds was collected using the information P provided.
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P, a whistleblower, provided information to R. Using P's information, R commenced examinations of a taxpayer that led to the assessment and collection of almost $20 million. R determined that slightly less than $2 million of the collected proceeds was collected using the information P provided. R further determined that because less than $2 million was based on P's information, the $2 million threshold for application of the nondiscretionary award regime of I.R.C. sec. 7623(b) had not been met. Accordingly, R made a discretionary whistleblower award under I.R.C. sec. 7623(a). P argues that…
1Opinion of the Court
IAN D. SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Smith v. Comm'r
Docket No. 25605-15W.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 23; 148 T.C. No. 21; 113 T.C.M. (CCH) 4077;
June 7, 2017, Filed
An appropriate order will be issued.
P, a whistleblower, provided information to R. Using P's information, R commenced examinations of a taxpayer that led to the assessment and collection of almost $20 million. R determined that slightly less than $2 million of the collected proceeds was collected using the information P provided. R further determined that because less than $2…
2Cases cited13 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Caminetti v. United StatesSupreme Court of the United States · 1917
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Greyhound Corp. v. Mt. Hood Stages, Inc.Supreme Court of the United States · 1978
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Whistleblower 14376-16W v. Comm'rUnited States Tax Court · 2017