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Case: Tax Court Cannot Order IRS to Reopen Whistleblower Examination on Target (D.C. Cir.) (IRC §6213)

June 17, 2020, 5:00 AM

Whistleblower award affirmed but ordering IRS to reopen target’s estate tax for further examination denied, the D.C. Circuit Court of Appeals held. Whistleblower was involved in a lawsuit with Estate and filed a Form 211 reporting that Estate understated its tax by several million dollars by failing to include several assets on its return. Estate was already being investigated, but the investigation was widened by the information supplied by Whistleblower’s Form 211. The IRS ended up collecting almost $424,000. Whistleblower received a recommendation for a preliminary award of $43,000, but he disagreed with the recommendation, arguing that the IRS’s adjustments...

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