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Thursday, May 7, 2026

Case: Tax Court Lacks Jurisdiction to Review Appeal of ... - Bloomberg Tax

Appeal of whistleblower award claim rejection was dismissed, the U.S. Tax Court held in a memorandum opinion, for lack of subject matter jurisdiction, as required by legal precedent set under Li v. Commissioner, 22 F.4th 1014 (D.C. Cir. 2022). The court reasoned that, as the IRS Whistleblower Office declined to proceed with any administrative or judicial action based on petitioner’s claim, there is no “determination regarding an award” as required by I.R.C. §7623(b)(1), which governs Tax Court jurisdiction with respect to whistleblower award cases. [McCrory v. Commissioner, T.C. Memo 2023-51 (Apr. 20, 2023)]

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