The administrative record shows that the Whistleblower Office’s denial of award was consistent with Treasury regulations defining when a whistleblower’s contribution is sufficient to justify an award, and the determination letter sufficiently explained the Office’s reasoning, the D.C. Circuit Court of Appeals held, affirming the Tax Court’s decision in favor of the IRS. [Villa-Arce v. Commissioner, No. 22-1006 (D.C. Cir. May 26, 2023)]
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