Tax Court Has Limited Power in Fight Over Whistleblower Award

The U.S. Tax Court said it doesn’t have the power to redetermine the tax liability of an entity targeted by an IRS whistleblower complaint.

The court said that it has the power to review the IRS’s whistleblower award determination, but that doesn’t give it power to “review the Commissioner’s determinations of the alleged tax liability to which the claim pertains,” according to an Oct. 21 opinion.

Vincent J. Apruzzese requested an award from the IRS Whistleblower Office on Sept. 16, 2011, alleging that the target of a complaint from him and a co-complainant failed to ...