Another look at Cooper v. Commissioner.

I wanted to highlight an article published in the September 19, 2011, issue of Tax Notes, “Scratching Our Heads Over Cooper v. Commissioner“ by Michelle M. Kwon.  In this article, Ms. Kwon gives a thoughtful discussion of the Tax Court’s jurisdiction to hear IRS whistleblower cases.  She explores the implications of the court’s decision and some of the questions left unanswered. 

Ms. Kwon has previously written on how in creating the whistleblower program Congress created tension between the IRS and the whistleblower due to the confidentiality restrictions in Section 6103 in “Whistling Dixie About the IRS Whistleblower Program Thanks to the IRC Confidentiality Restrictions,” originally published in the Winter, 2010, edition of the Virginia Tax Review, 29 Va. Tax Rev. 447.