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Tuesday, April 7, 2026

Case: Whistleblower Appeal Premature Without IRS Award Determination Letter (DC Cir.) (IRC §7623) - Bloomberg Tax

Appeal of whistleblower action premature as the IRS had yet to issue an award determination under I.R.C. §7623, the D.C. Circuit Court of Appeals held in affirming the district court. The district court also correctly concluded that, even if an award determination had been made, the Tax Court has “exclusive” jurisdiction to review a subsequent appeal, the court stated. [Pinnavaia v. IRS, No. 21-5228 (D.C. Cir. Feb. 23, 2022) (unpub. op.)]

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