by Stephen U. McCloskey, Jr. | Jul 25, 2013 | Administration of Whistleblower Claims, Award Determinations, Guidance, Judicial Review, Whistleblower Awards
An order issued yesterday by the U.S. Tax Court in the case of Albert G. Hill, III v. Commisioner of Internal Revenue (No. 25539-10W) gave the Whistleblower (who is the Petitioner in the case) access to documents in the administrative file of the taxpayer who was the...
by Lynam Knott | Apr 24, 2013 | Administration of Whistleblower Claims, Award Determinations, IRS Whistleblower Office, Judicial Review
Joseph Insinga’s case has been watched closely from the time the petition was filed to see if the Tax Court would assert jurisdiction over a case where the IRS had not issued a formal determination but had allowed the claim to linger, causing a de facto denial...
by Lynam Knott | Mar 13, 2013 | Award Determinations, IRS Whistleblower Office, Judicial Review
The IRS has spent much time ensuring that they would not be whipsawed by paying an award on proceeds that is ultimately refunded to the taxpayer, but apparently, little consideration has been given to what happens when the IRS whipsaws a whistleblower using their...
by Lynam Knott | Dec 10, 2012 | Administration of Whistleblower Claims, Guidance, Judicial Review
The Eleventh Circuit released Ware v. Commissioner, an unpublished opinion, in which the Eleventh Circuit upheld the Tax Court’s dismissal of the pro se taxpayers’ request for redetermination of their tax liability and their whistleblower claim. The...
by Lynam Knott | Oct 10, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review
The Tax Court dismissed a whistleblower’s complaint that challenged the IRS’s decision not to act on the whistleblower’s information. In Raymond Cohen v. Commissioner of Internal Revenue, 139 T.C. No. 12 (October 9, 2012), the Tax Court holds...
by Lynam Knott | Sep 18, 2012 | Administration of Whistleblower Claims, Guidance, IRS Whistleblower Office, Judicial Review
As discussed in an earlier blog post, the Tax Court formally adopted amendments to the Tax Court Rules of Practice and Procedure on July 6, 2012. The amendments rules include Rule 345, which provides that a whistleblower may proceed anonymously by redacting the...
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