Resources

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2020.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2019.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2018.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2017.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2016

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2015.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2014.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2013.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2012.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2011.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2010.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2009.

The IRS Whistleblower Office’s report to Congress for the IRS’s fiscal year ended September 30, 2008.

The IRS Whistleblower Office’s first annual report to Congress on the status of the program after the first 12 months.

Reissued interim guidance that adds new sections to the Internal Revenue Manual regarding the reduction of withholding on whistleblower awards.

Reissued interim guidance that provides updates to the Internal Revenue Manual which outlines procedures for making partial award payments and refund netting, a procedure whereby whistleblowers are eligible for awards on amounts that act as offsets to adjustments made or refunds denied as a result of the whistleblower’s information.

Reissued interim guidance that provides updates to the Internal Revenue Manual to outline procedures for whistleblower award determination administrative proceedings, allowing a whistleblower to contest the proposed award in an administrative proceeding with the IRS before a final award determination is made.

Reissued interim guidance that adds new sections to the Internal Revenue Manual that will reduce withholding on whistleblower awards.

 Updates the Internal Revenue Manual to outline procedures for making partial award payments and refund netting, a procedure whereby whistleblowers are eligible for awards on amounts that act as offsets to adjustments made or refunds denied as a result of the whistleblower’s information.

Updates the Internal Revenue Manual to outline procedures for whistleblower award determination administrative proceedings, allowing a whistleblower to contest the proposed award in an administrative proceeding with the IRS before a final award determination is made.

Adds new sections to the Internal Revenue Manual that will reduce withholding on whistleblower awards.

(June 18, 2010) Internal IRS procedures for the payment of claims for awards to whistleblowers.

Reissued interim guidance that provides updates to the Internal Revenue Manual regarding procedures for making partial award payments and refund netting, a procedure whereby whistleblowers are eligible for awards on amounts that act as offsets to adjustments made or refunds denied as a result of the whistleblower’s information.

Reissued interim guidance that provides updates to the Internal Revenue Manual regarding procedures for whistleblower award determination administrative proceedings, allowing a whistleblower to contest the proposed award in an administrative proceeding with the IRS before a final award determination is made.

Brief overview of the IRS whistleblower claim process and information regarding submission of a claim to the IRS Whistleblower Office.

Deputy Commissioner John Dalrymple’s directive reaffirms and updates the internal deadlines set by Steven Miller’s 2012 directive and adds that Business Performance Review reports should include data on cases for which a risk analysis has been requested but not received for more then 30 days.

Final Treasury Regulations, effective August 12, 2014, which provide rules for governing whistleblowers under section 7623. These rules specifically include rules for submitting information and filing claims for awards, outline whistleblower administrative proceedings applicable to claims for awards, and addresses the computational determination and payment of awards (previously Final regulations that provide comprehensive guidance for the award program authorized under Internal Revenue Code section 7623. Final Treasury Regulation sections 301.6103(h)(4)-1 and 301.7623-1 through 301.7623-4).

Proposed Treasury Regulations, published on December 14, 2012, that propose rules for governing whistleblowers under section 7623. These rules specifically include rules for submitting information and filing claims for awards, outline whistleblower administrative proceedings applicable to claims for awards, and addresses the computational determination and payment of awards.

IRS internal memorandum concluding that amounts recovered for violation of non-tax laws may not be considered for purposes of computing an award under section 7623.

Deputy Commissioner Steven T. Miller’s directive imposes formal internal deadlines for reviewing whistleblower submissions by the whistleblower office and operating divisions, and it imposes a formal deadline by when whistleblowers should be notified of an award determination.

The treasury regulation was adopted unchanged from the proposed regulation, which extended the definition of “proceeds of amounts collected” and “collected proceeds” to include amounts collected prior to receipt of the whistleblower’s information if the information provided results in the denial of a claim for refund, or a reduction of an overpayment credit balance used to satisfy a tax liability incurred.

IRS internal memorandum concluding that Form 211R, Declaration of Representation for Whistleblower Claim, as written, does not adhere to the requirements of a valid power of attorney and cannot be accepted by the IRS as a valid power of attorney.

The IRS cannot accept a Form 2848, Power of Attorney and Declaration of Representative, or other power of attorney that has been altered or modified so that the power of attorney not longer complies with the established rules and regulations regarding powers of attorney for whistleblower representatives.

IRS internal memorandum concluding that employees of the Whistleblower Office are authorized to disclose taxpayer return information to whistleblowers in making determinations pursuant to section 7623, or providing status updates to whistleblowers regarding pending, unprocessed, or dismissed claims under section 7623. The specific taxpayer return information that may be disclosed to a whistleblower in a particular instance will depend on the facts and circumstances of the matter.

IRS internal memorandum concluding that an award paid under section 7623 to a nonresident alien individual is characterized as compensation for services and taxes must be withheld under section 1441 on the U.S. source portion of the award payment unless specifically exempted by treaty.

IRS internal memorandum concluding that it is permissible to withhold potential income tax on whistleblower awards under section 7623(a), as there is no legal or factual basis for differentiating between the federal tax treatment of payments made under section 7623(a) and (b), and that a de minimis exception to administrative withholding is legally supportable.

IRS internal memorandum stating that the IRS’s decision to withhold on whistleblower awards under section 7623 is legally defensible even though they have no specific statutory authority to withhold on these awards.

IRS internal memorandum concluding that including refunds not issued and the elimination or reduction of credit balances in collected proceeds is not only a legally permissible interpretation of that term, it would be consistent with the purpose of section 7623.

IRS internal memorandum concluding that criminal fines are not part of collected proceeds because all criminal fines collected for offenses against the United States government are required to be deposited in to the Crime Victims Fund, except those specifically excluded, under the Victims of Crime Act of 1984.

Final Treasury Regulations on the disclosure of return information under section 6103(n) in connection with written contracts among the IRS, whistleblowers, and legal representatives of whistleblowers, for services concerning the detection of violations of the internal revenue laws or related statutes.

This Notice modifies Notice CC-2008-011 by loosening the limitations on the IRS’s ability to contact Whistleblowers who are current employees of a taxpayer.

Treasury Regulations published on January 18, 2011 that propose extending the definition of “proceeds of amounts collected” and “collected proceeds” to include amounts collected prior to receipt of the whistleblower’s information if the information provided results in the denial of a claim for refund, or a reduction of an overpayment credit balance used to satisfy a tax liability incurred.

Final Regulations requiring corporations to file a schedule disclosing uncertain tax positions taken on the tax return for years beginning on or after January 1, 2010.

Internal IRS procedures for processing cases to be analyzed by the IRS Small Business/Self-Employed Division.

Internal IRS procedures for analyzing informant information and disseminating it to the audit team in the IRS Large and Mid-Size Business Division.

“Limitations on Informant Contacts: Current Employees and Taxpayer Representatives”

This Notice provides guidance to the public on how to file claims under Internal Revenue Code section 7623 as amended by the Tax Relief and Health Care Act of 2006.

This Notice provides guidance relating to a new cause of action in the Tax Court for review of award determinations made by the Service’s Whistleblower Office, pursuant to section 7623.

Based on the old Informant’s Rewards Program.

This law, passed on December 20, 2006, established the IRS Whistleblower Office, required annual reports to Congress, added the section 7623(b) enhanced whistleblower award provisions, and provided for an above the line deduction for attorney’s fees in section 7623(b) cases.

This law, passed on February 9, 2018, added a section (c) to section 7623 and expanded the definition of collected proceeds to include more than just those amounts collected under Title 26 (i.e. the Internal Revenue Code).

This law became law on July 1, 2019, adding (1) anti-retaliation provisions to section 7623, bringing the IRS whistleblower program into conformity with other federal whistleblower programs; and (2) provisions that allow the IRS to share certain information with whistleblowers regarding the status and stage of their claims.

TIGTA determined that the Whistleblower Program has helped identify noncompliance and helped the IRS collect significant amounts of revenue; however, improvements are still needed to ensure that claims are processed appropriately and expeditiously.

Billions Collected, but Timeliness and Communication Concerns May Discourage Whistleblowers (October 2015)  – This GAO report shows that while the program has successfully brought in nearly $2 billion in additional collected proceeds, the timeliness of certain actions and communications need to be improved.

Koskinen’s statement affirming his commitment and support to the IRS Whistleblower Program.

TIGTA auditors determined that the process for individuals to report suspected tax law violations is not efficient or effective.

(April 30, 2012) TIGTA auditors determined that improved oversight is needed to effectively process whistleblower claims.

(Letter to Commissioner Shulman from Senate Finance Committee member Charles Grassley, dated September 13, 2011, urging the IRS to incorporate the changes to the IRS’s Whistleblower Program regarding claim processing and reporting key information to Congress outlined in Government Accountability Office report GAO-11-683).

“TAX WHISTLEBLOWERS – Incomplete Data Hinders IRS’s Ability to Manage Claim Processing Time and Enhance External Communication” This GAO Report addressed how improved tracking of cases by the IRS could improve the Whistleblower Program, decrease delays, and aid Congress’s ability to oversee it.

(Senate Finance Committee member Charles Grassley calls on government officials to follow the road map provided in the Government Accountability Office report for how to improve the IRS Whistleblower Office, urging Treasury and IRS officials to “do all they can to ensure the success of what’s clearly one of the best tools available to go after tax fraud.”)

(Letter to Commissioner Shulman from Scott A. Knott and Gregory S. Lynam, The Ferraro Law Firm Tax Partners, urging the IRS to take action to reconcile conflicting guidance issued by Chief Counsel with respect to whether “collected proceeds” under section 7623 include denied claims for refund, and when whistleblower award determinations are eligible to be made).

(April 8, 2011) (Senate Finance Committee member Charles Grassley applauded the IRS’s use of information provided by a whistleblower to recover $20 million that might otherwise have taken years of work by the IRS to uncover or missed entirely).

The announcement explains the IRS is expanding its policy of restraint in connection with its decision to require certain corporations to file Schedule UTP, Uncertain Tax Position Statement, and will forgo seeking particular documents that relate to uncertain tax positions and the workpapers that document the completion of Schedule UTP.

The announcement explains the actions being taken by the IRS in response to the comments received on the proposed schedule and instructions for the reporting of uncertain tax positions.

Letter to Secretary Geithner from Senate Finance Committee ranking minority member Charles Grassley, dated June 21, 2010, requesting a delay in the implementation of the new Internal Revenue Manual provisions until these provisions can be more fully evaluated

(August 20, 2009) “DEFICIENCIES EXIST IN THE CONTROL AND TIMELY RESOLUTION OF WHISTLEBLOWER CLAIMS” This TIGTA report evaluated how the IRS has implemented the enhanced IRS Whistleblower Program. TIGTA found that the IRS did not have an effective inventory control system or adequate procedures and processes in place, creating inaccuracies and inconsistencies among control systems. The report recommends that the new single inventory control system should include reporting capabilities, written procedures with timeliness standards should be established, and processes to monitor the timely processing of claims should be developed. The IRS agreed with the recommendations and began to take corrective action.

United States Tax Court Washington, D.C., October 3, 2008 Press Release

Which he has championed in Congress for two decades.

The first Director of the new IRS Whistleblower Office

The Informants’ Rewards Program Needs More Centralized Management Oversight June 2006 audit report by the Treasury Inspector General for Tax Administration of the old tax whistleblower program

Internal IRS procedures for processing cases to be analyzed by the IRS Large and Mid-Size Business Division.

The Tax Court held that Respondent did not abuse its discretion in rejecting Petitioner’s whistleblower claim and granted summary judgement for Respondent.

The Tax Court granted Respondent’s motion for summary judgement, contending that the Whistleblower Office did not abuse its discretion by denying and/or rejecting claims by Petitoner after reviewing Petitioner’s claim

The Tax Court granted Respondent’s motion for summary judgement, contending that the Whistleblower Office did not abuse its discretion by rejecting the claim by Petitioner on the grounds that it was speculative and did not provide any specific or creditable information regarding

The Tax Court held that IRS did not abuse its discretion by subjecting Petitioner’s IRS whistleblower award to federal budget sequestration.

The Tax Court held that The WBO did not abuse its discretion when it denied P’s first claim, where the IRS did not collect any proceeds, and rejected P’s second claim, for failing to provide specific or creditable information.

The Tax Court granted the IRS’s motion for summary judgement where no additional tax, penalties, interest, or amounts assessed or collected; and denied Petitioner’s motion for summary judgement that the Tax Court interprited as the IRS failing to assess or collect any additional tax, penalties, interest, or other amounts.

The Tax Court held that the Whistleblower Office did not abuse its discretion in rejecting the Petitioner’s claim as speculative where the Whistleblower Office could not identify the persons or entities alledged to violated any tax laws, and that the information provided was speculative and/or did not provide specific or creditable informaiton regarding tax underpayments or violations of internal revenue laws.

The Tax Court held that it has jurisdiction to review the Whistleblower Office’s decision to reject a claim for failing to meet certain threshold requirements.

The Tax Court held that Petitioner was not entitled to a larger award than the Whistleblower Office determined under section 7623(a).

The DC Circuit held that the Tax Court abused its discretion because identifying Appellant is not necessary to enable the public to gauge (1) the extent to which serial filers affect the work of the Tax Court or (2) whether a particular petitioner is a serial filer. The case was remanded to the Tax Court for reconsideration.

The Tax Court held that the Whistleblower Office did not abuse its discretion to deny the Petitioner’s claim for award where the operating division determined that taxpayer was properly reporting interest income that was the subject of Petitioner’s Form 211.

The DC Circuit reversed the Tax Court’s dismissal and remanded the case for further proceedings because, although Myers’s petition was untimely, the filing period is not jurisdictional and is subject to equitable tolling.

The Tax Court held that in appropriate circumstances the Tax Court may remand a whistleblower case to the Whistlblower Office.

The Tax Court held that a letter subsequent to a Final Determination that stated that the claim had previously been denied in response to Petitioner providing additional information to the Whistleblower Office that was not available to Petitioner when the claim was denied was a determination for purposes of confering jurisdiction to the Tax Court.

The Tax Court granted Respondent’s motion for summary judgment because the IRS Whistleblower Office did not initiate any administrative or judicial action against any taxpayer and did not collect any proceeds on the information provided by Petitioner.

The Tax Court granted Respondent’s motion for summary judgement where Respondent’s examination ended in no change to the tax status of the bonds.

The Tax Court granted Respondent’s motion for summary judgement where Respondent’s examination ended in no change to the tax status of the bonds.

The Tax Court denied Petitioner’s motion to proceed anonymously because Petitioner had previously disclosed his whistleblowing activites when he thought that it would be beneficial and no longer works in the same field.

The Tax Court granted Respondent’s motion for summary judgement where Respondent did not initiate any administrative or judicial action on the basis of Petitioner’s information and did not collect any proceeds.

The Tax Court granted Respondent’s motion for summary judgement where Respondent did not initiate any administrative or judicial action on the basis of Petitioner’s information and did not collect any proceeds.

The Tax +B49:B95+B49:B97+B49:B97ve record; however, the administrative record may be supplemented where it is incomplete or an exception applies. The Tax Court also held that the standard of review is abuse of discretion when reviewing determinations under section 7623(b).

The Tax Court denied Respondent’s motion for summary judgement because material question of fact existed.

The Tax Corut held that because the Whistleblower Office completed its consideration of Petitioner’s whistleblower claim, and at no time did it initiate an administrative or judicial appeal or collect any tax proceeds from the target taxpayer that Petitioner is not entitled to relief from the Whistleblower Office’s determination under section 7623(b)

The Tax Court denied Petitioner’s motion to proceed anonymously because the Tax Court determined that the public’s interest in identifying a serial whistleblower outweighs the Petitioner’s interest in anonymity.

The Tax Court held that because Petitioner’s information that formed the basis for Petitioner’s claim for an award was provided prior to enactment of section 7623(b), the Tax Court lacked the authority to review Respondent’s determination.

The Tax Court held that because the administrative action taken by the IRS against the taxpayer was not based on Petitioner’s information, Petitioner is not entitled to a whistleblower award.

The Tax Court held that the IRS had not established all of the facts necessary to prove its affirmative defense that less than $2 million was at issue because the IRS had not established that records of departments or office, other than the Whistleblower Office, did not have documents or records that are relevant to whether the amount in dispute in this matter exceeded $2 million.

The Tax Court held that the IRS had not established all of the facts necessary to prove its affirmative defense that less than $2 million was at issue because the facts alleged in respondent’s motion do not preclude the existence of other records showing that the amount in dispute exceeded $2 million.

The Tax Court held that the “amounts in dispute” referenced in section 7623(b)(5)(B) are the total amount of the liability that the IRS proposed with respect to a taxpayer’s examination that was commenced using the information provided by a whistleblower and are not limited to the part of “collected proceeds” attributable to the whistleblower’s information.

The Tax Court held that each of the letters stating that the Whistleblower Office had considered the additional information that Petitioner provided constituted an appealable determination for purposes of section 7623(b)(4). The Tax Court held, further, that where there is direct evidence that a claimant received actual notice of an award determination without prejudicial delay and sufficent time to file a petition, that notice is effective to commence the running of the 30-day periodin section 7623(b)(4); and Petitioner received actual notice of the Whistleblower Office’s determination without prejudicial delay and had ample opportunity to file a petition, but Petitioner filed significantly after 30 days after he recevied actual notice of the determination.

The Tax Court held that when a whistleblower agrees to accept an award, that agreement with the IRS – which includes a waiver of the right to judicial review – is binding and therefore the petitioner was precluded from challenging the amount of the award.

The Tax Court granted Resondent’s motion for summary judgment because the IRS Whistleblower Office did not initiate any administrative or judicial action on the basis of the information Petitioner provided and did not collect any proceeds as a result of that information.

The Tax Court held that Petitioner was not entitled to an award because there were no collected proceeds for years 2006 through 2008 and no adminsitrative or judicial actions taken for years after 2008. The Tax Court held, further, that the Commissioner is not required to monitor a taxpayer’s voluntary change in reporting for years for which there was no action.

The Tax Court held that Petitioner may proceed anonymously until and unless the Court determines differently in a case where Petitioner is seeking review of the IRS’s denial of Petitioner’s whistleblower claim.

The Tax Court granted Petitioner’s motion to voluntarily dismiss her case because Respondent would not suffer any prejudice, applying the principles of Wagner v. Commissioner, 118 T.C. 330 (2002).

The Tax Court held that Delegation Order 25-7 properly delegated the authority to issue determination letters to the Whistleblower Office staff; that a determination letter that is not mailed to Petitioner’s last known address and not received is not valid; and that Petitioner timely petitioned the Tax Court based on the proeprly remailed notice of determination.

The Tax Court held that the phrase “collected proceeds” is sweeping in scope and is not limited to amounts assessed and collected under Title 26 of the United States Code and that criminal fines as well as civil forfeitures are collected proceeds under section 7623(b).

The Tax Court granted Petitioner’s motion to compel discovery where Respondent had not convinced the Court that the discovery was not material or that it was not relevent.

The Tax Court denied Respondent’s motion to dismiss for lack of jurisdiction because Respondent could not establish the mailing of the final determination letter sufficently to satisfy established in Kasper.

The Tax Court held that the term “additional amounts” as used in section 7623(b)(5)(B) means civil penalties set forth in chapter 68, subchapter A of the Internal Revenue Code.  The Court further held that FBAR civil penalties are not “additional amounts” within the meaning of section 7623(b)(5)(B), and they are not “assessed, collected, … [or] paid in the same manner as taxes.”

The Tax Court held that the IRS cannot unilaterally decide what constitute the administrative record after the IRS objected to several discovery requests on the ground that the requested information was outside the administrative record compiled by the IRS Whistleblower Office.

The Tax Court held that the fact that a whistleblower supplied their information to other Federal agencies, including an IRS operating division, before submitting the information to the IRS Whistleblower Office on Form 211 does not, as a matter of law, render the whistleblower ineligible for an award under section 7623(b).

The Tax Court held that the $2 million requirement in section 7623(b)(5)(B) is an affirmative defense and is not jurisdictional.

The Tax Court held that the Tax Court retains jurisdiciton over a determination to deny a whistleblower an award when the Whistleblower Office decides to further consider an whistlblower’s application for an award after the Whistleblower Office mailed a final denial letter and the whistleblower appealed that denial to the Tax Court.

The Tax Court denied Respondent’s motion to dismiss for lack of jurisdiction finding that the letter responding to additional information was a determination for purposes of section 7623(b)(4).

Tax Court lacks jurisdiction to hear a case where the claim remains open and the IRS has not yet made an administrative decision on the claim.

The Tax Court held that it has jurisdiction to review the IRS’s determination of the whistleblower claim where the whistleblower has alleged that they provided information to the IRS before and after the effective date of section 7623(b). In the pleadings, the whistleblower alleged that the information they provide post-December 2006 was significant and not simply confirmatory details.

The Tax Court held that it has jurisdiction to review the IRS’s determination of the whistleblower claim where the whistleblower has alleged that they provided information to the IRS before and after the effective date of section 7623(b). In the pleadings, the whistleblower alleged that the information they provide post-December 2006 was significant and not simply confirmatory details.

The Tax Court granted a whistleblower’s motion to proceed anonymously, finding that the risk of harm to the whistleblower outweighs the public interest in knowing the whistleblower’s identity.The whistleblower had provided the IRS information on the whistleblower’s former employer.The whistleblower was retired and relied on retirement benefits the whistleblower received from the former employer.

The Tax Court granted a whistleblower’s motions to proceed anonymously and to seal the record, finding that the whistleblower had demonstrated that failing to seal the record could result in severe physical harm and that proceeding anonymously is necessary to protect the whistleblower’s safety. The whistleblower has already suffered from actions intended to threaten and discourage the whistleblower from disclosing information after the whistleblower was subpoenaed by the Government.The whistleblower received a death threat from the targets, communicated through their counsel, and the Government offered to place the whistleblower in the witness protection program.

The Tax Court granted a whistleblower’s motion to proceed anonymously, finding that proceeding anonymously is necessary to protect the whistleblower’s professional reputation, economic interests and personal safety.The whistleblower reported a tax fraud scheme to the government involving targets with alleged links to terrorist organizations and had used physical force and armed men to intimidate the whistleblower and prevent disclosure.

The Tax Court dismissed a whistleblower’s challenge to the IRS’s decision not to pursue a lead he provided and denied his petition to force the IRS to reopen his award claim, holding that the Tax Court is not authorized by section 7623(b) to order the IRS to reopen a claim or to order the IRS to pursue particular information provided.

(Holding that the potential harm from disclosing a whistleblower’s identity as a confidential informant outweighs the public interest in knowing the whistleblower’s identity, and that redacting identifying information adequately protects the whistleblower’s legitimate privacy interests as a confidential informant.)

Granting the IRS’s motion to dismiss for lack of jurisdiction because the Petitioner failed to timely filing a petition with the Tax Court to appeal his adverse whistleblower award determination. It is important to note that the IRS argued that the letter mailed to the Petitioner denying an award was an administrative decision, thus apparently acquiescing to the Court’s ruling on that issue in Cooper.

Holding that the 30-day period to petition the Tax Court under section 7623(b)(4) begins on the date of mailing of the determination by the Whistleblower Office, and the IRS must prove by direct evidence the date and fact of mailing of the determination to the whistleblower.

Holding that the Tax Court’s jurisdiction in a whistleblower case does not include opening or ordering the IRS to open an administrative or judicial action to redetermine the tax liability.

Holding that the Tax Court has jurisdiction to review the IRS’s denial of an individual’s whistleblower claims, finding that an IRS letter to the individual denying his claims constitutes a “determination” under section 7623(b)(4), following Cooper v. Commissioner. But dismissed the case because the individual failed to file a timely petition with the court, within 30 days of the original denial letter.

In a case of first impression, the Tax Court held that an IRS letter denying whistleblower awards constitutes a final administrative determination necessary to allow the court to review the petitioner’s claim, and denied the IRS’s motion to dismiss.

The Court of Federal Claims dismissed actions against the government for whistle-blower rewards finding that the Tax Court has sole jurisdiction, there is no contractual claim, and transfer of the case to the Tax Court is not statutorily permissible.

The Tax Court denied an untimely request for a reward under the tax whistleblower provisions.