Case: Speculative Information on Target’s U.S. Citizenship Allows Whistleblower Office to Reject Claim (T.C. Memo) (IRC §7623)

Administrative record enough to show IRS followed proper procedures in rejecting a whistleblower’s claim due to speculative information, the U.S. Tax Court held in a memorandum opinion. Whistleblower (W) submitted a Form 211 claiming that Target, an individual dual-citizen, failed to pay U.S. federal income taxes. On the Form 211, W did not include Target’s Social Security number or other U.S. citizenship identification but referenced “N/A Foreign National.” The IRS Whistleblower Office (WBO) rejected the claim as too speculative. W sought the court’s review. In rejecting W’s request for remand back to the IRS, the court found the administrative record ...