WHISTLEBLOWER 11099-13W,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
United States Tax Court
Filed January 13, 2026
P applied for a whistleblower award, alleging a scheme under which T manipulated its inventory purchases to inflate artificially its cost of goods sold, which T determined using the last-in, first-out (LIFO) inventory accounting method. R investigated P's allegations but could not confirm them. T subsequently changed its inventory accounting method from LIFO to first-in, first-out (FIFO). P seeks a whistleblower award based on the additional tax he claims T reported and paid because of T's cessation of its allegedly manipulative inventory purchases and the change to its inventory accounting method.
A whistleblower is eligible for an award only if R “proceeds with any administrative or judicial action . . . based on information” supplied by the whistleblower and collects proceeds “as a result of the action.” I.R.C. §7623(b)(1). R has moved for summary judgment that he did not abuse his discretion in denying P's application for an award because the administrative record “evinces that [P's] information could not be substantiated; that the [IRS] was unable to detect the tax noncompliance alleged by [P]; and that it collected no proceeds from the investigation of [P's] claim.” Moreover, R adds, even accepting as fact P's allegations that T abandoned manipulative inventory practices and then abandoned LIFO, those facts are [*2] immaterial, because...
Donald Trump's claim that Nato troops avoided the front line in Afghanistan has sparked widespread outrage among veterans and their families. Ben Parkinson, a severely injured British paratroope...