Whistleblower 14106-10W v. Commissioner
United States Tax Court
P, a former senior executive of X, filed a claim for a whistleblower award under sec. 7623(b), I.R.C., alleging that X had underpaid its taxes. R investigated P's claim but did not open an administrative or judicial proceeding against X and did not collect any additional tax from X on the basis of P's information. R denied P's claim on the basis that an award determination could not be made under sec. 7623(b), I.R.C. P's identity thus far has been kept confidential.
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P, a former senior executive of X, filed a claim for a whistleblower award under sec. 7623(b), I.R.C., alleging that X had underpaid its taxes. R investigated P's claim but did not open an administrative or judicial proceeding against X and did not collect any additional tax from X on the basis of P's information. R denied P's claim on the basis that an award determination could not be made under sec. 7623(b), I.R.C. P's identity thus far has been kept confidential. Asserting that disclosing P's identity in this judicial proceeding would result in retaliation and professional ostracism, P…
1Opinion of the Court
WHISTLEBLOWER 14106-10W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Whistleblower 14106-10W v. Comm'r
Docket No. 14106-10W
United States Tax Court
137 T.C. 183; 2011 U.S. Tax Ct. LEXIS 47; 137 T.C. No. 15; 76 A.L.R. Fed. 2d 713;
December 8, 2011, Filed
An appropriate order will be issued, and order and decision will be entered for respondent.
P, a former senior executive of X, filed a claim for a whistleblower award under sec. 7623(b), I.R.C., alleging that X had underpaid its taxes. R investigated P's claim but did not open an administrative or judicial proceeding against X and did…
Also in this document: Concurrence.
2Cases cited70 opinions
- Roe v. WadeSupreme Court of the United States · 1973
- Nixon v. Warner Communications, Inc.Supreme Court of the United States · 1978
- Lugosch v. Pyramid Co. of OnondagaCourt of Appeals for the Second Circuit · 2006
- Roviaro v. United StatesSupreme Court of the United States · 1957
- Richmond Newspapers, Inc. v. VirginiaSupreme Court of the United States · 1980
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