WHISTLEBLOWER 20442-18W,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
United States Tax Court
Filed August 11, 2025
Adam L. Pollock, for petitioner.
Aimee R. Lobo-Berg, Matthew A. Cappel, Zachary A. Gray, Darrick D. Sun, Sophia L. Wang, and Julie V. Skeen, for respondent.
MEMORANDUM OPINION
LAUBER, Judge: In this whistleblower award case petitioner seeks review pursuant to section 7623(b)(4)1 of a final decision by the Internal Revenue Service (IRS or respondent) to deny a claim for an award. The IRS teams that conducted the examination of the target taxpayer made “adjustments to several issues related to the whistleblower allegations.” But the claim was denied “because the IRS identified the issues prior to receipt of [petitioner's] information and [the] information did not substantially contribute to the actions taken by the IRS.”
Respondent has filed a Motion for Summary Judgment contending that the denial of petitioner's claim was not an abuse of discretion.
[*2] In so contending respondent relies in part on Treasury Regulation §301.7623-2(b)(1), which defines the statutory phrase “proceeds based on.” That regulation explains that “the IRS proceeds based on information provided by a whistleblower when the information provided substantially contributes to an action against a person identified by the whistleblower.” Because petitioner's information did not “substantially contribute” to the adjustments made during the examination, respondent contends that...
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