Case: U.S. District Court Upholds IRS Discretion in Whistleblower Award Determination

The U.S. District Court upheld the IRS’s determination of a whistleblower award under IRC §7623(a), dismissing the taxpayer’s challenge. The taxpayer, who provided information to the IRS about a company’s tax evasion scheme, received a $10 million whistleblower award under §7623(a). The taxpayer challenged the award amount, arguing the IRS failed to properly apply regulatory factors in determining the award. The court held that the IRS’s discretion in awarding §7623(a) claims was not limited by the applicable Treasury regulations or IRS guidance, which did not provide judicially manageable standards for reviewing the award determination. The court also dismissed the taxpayer’s ...