Case: Tax Court Lacks Jurisdiction to Review Rejection of Whistleblower Claim for Vague, Speculative Information (D.C. Cir.) (IRC §7623)

The Tax Court lacks jurisdiction to hear appeals from threshold rejections of whistleblower award requests, the D.C. Circuit Court of Appeals held in rejecting the precedents of two Tax Court opinions finding such jurisdiction. A threshold rejection of a whistleblower’s Form 211 for vague and speculative information is not a negative award determination, as there is no determination as to an award under I.R.C. §7623(b)(1)-(3) whatsoever, the court concluded. The IRS Whistleblower Office (WBO) rejected Whistleblower’s (W) Form 211 for providing vague and speculative information it could not corroborate, even after examining supplemental material W herself did not provide. The ...