The U.S. Tax Court lacks jurisdiction to review a case where the IRS took no action on a whistleblower’s resubmission of information that did not result in an award, the court held in a memorandum opinion granting the IRS’s motion to dismiss. Where the original submission (on alleged “skimming” operations at more than 200 restaurants) predates I.R.C. §7623(b)(4), which provides the predicate for the court’s jurisdiction, Petitioner argued unsuccessfully that the court has jurisdiction based not on when he submitted the information but rather on when the IRS used it — i.e., sought to corroborate it. A claimant ...
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