Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
For a link to our podcast covering the Tax Court in Brief, download here or check out other episodes of The Freeman Law Project.
Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W
Summary: Timothy J. Lewis submitted Form 211, Application for Award for Original Information, to the IRS’s Whistleblower Office (WBO) alleging underpayments in income tax by a closely held corporation. The WBO sent a letter to Lewis, stating that Lewis was entitled to a “mandatory” whistleblower award under 26 U.S.C. § 7623(b). The letter specified the total amount of the award and stated that, in accordance with law, the award would automatically be reduced by what is referred to as a sequestration reduction. Lewis appealed the final determination letter to the Tax Court and argued that it was inappropriate for the WBO to apply the sequestration reduction to the award. The Tax Court upheld the sequestration reduction. The WBO then issued Lewis a whistleblower award check, which included the applicable sequestration reduction. Lewis thereafter again petitioned the Tax Court, challenging the appropriateness of the sequestration reduction and arguing that...
A wave of pro-whistleblower opinions from federal judges suggests the False Claims Act remains on solid ground despite pointed questions from leading conservative judicial voices. Whistleblowers, ...