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Saturday, May 16, 2026

Eleventh Circuit Affirms Dismissal of Whistleblower Award Case - Tax Notes

WILLIAM S. SCOTT,
Plaintiff-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE SERVICE,

Defendant-Appellee.

In the United States Court of Appeals
For the Eleventh Circuit

Appeal from the United States District Court for the Southern District of Florida

Non-Argument Calendar

Before ROSENBAUM, GRANT, and BRASHER, Circuit Judges.

PER CURIAM:

William Scott, proceeding pro se, appeals the district court's dismissal of his complaint for lack of subject matter jurisdiction. Scott argues that the court had jurisdiction over his appeal from the Internal Revenue Service's denial of his whistleblower award application. He also argues that the district court judge's failure to recuse herself necessitates reversal. We affirm.

I.

This case arises from the IRS's denial of an award for a whistleblower claim. Scott submitted a Form 211 application for a whistleblower award. Under 26 U.S.C. §7623(b), where the IRS acts based on a whistleblower's information, the whistleblower will receive between fifteen and thirty percent of the amount collected as a result of the action.

The IRS denied Scott's claim. According to its letter, Scott was ineligible for an award because the information he provided did not result in the collection of any proceeds. Scott subsequently sued the Commissioner of the IRS, seeking an injunction directing the IRS to investigate his application for a whistleblower award. He framed his case as arising under the Administrative Procedure Act.

The district court dismissed his...



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