Case: Whistleblower Check After Receipt of Determination Letter Deprives Court From Jurisdiction (T.C. Memo) (IRC §7623)

May 9, 2022, 5:00 AM UTC

Receipt of a check for an award from the IRS Whistleblower Officer does not render separate jurisdiction on the Tax Court when the taxpayer received a determination letter as well, the U.S. Tax Court held in a memorandum opinion. Taxpayer filed a whistleblower complaint and received a final determination that he was entitled to an award. The letter stated that the award would be reduced by a sequestration amount. Taxpayer received the check. Taxpayer appealed to the Tax Court that the award should not be reduced by sequestration. The court held that it was proper for the IRS to reduce ...

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