Case: Whistleblower Request Properly Denied Without Collecting Proceeds From Target (T.C. Memo) (IRC §7623)

IRS Whistleblower Office (WBO) did not abuse its discretion when it denied a whistleblower award on the premise that no proceeds were collected on the basis of the information provided, the U.S. Tax Court held in a memorandum opinion. Whistleblower (W) brought a claim that an S corporation and its shareholders overstated costs of goods sold and claimed improper deductions on payments made from the majority shareholder to his daughter, the remaining shareholder. As a result, the IRS audited the returns with adjustments to net operating losses. However, the NOLs were carried forward resulting in no tax change since the ...