Court lacked jurisdiction to hear a whistleblower award case where the IRS had issued a threshold rejection of petitioner’s claim, the U.S. Tax Court held, granting the IRS’s motion to dismiss. The IRS had made no award determination under I.R.C. §7623(b). The IRS Whistleblower Office rejected petitioner’s claim for not meeting the $2 million threshold needed to qualify for a mandatory award, the information was not sent to an IRS examination team, and no action was taken based on the claim. [Raffaelli v. Commissioner, T.C. Memo 2023-79 (June 22, 2023)]
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