Whistleblower Rightly Denied Cut of $2.3 Billion Disclosure Pool

A whistleblower who sued the IRS for part of the government’s $2.3 billion recovery stemming from offshore banking disclosures had his lawsuit properly dismissed, a federal appeals court said in an opinion unsealed Wednesday.

Thomas Shands received criminal immunity and an $8.5 million reward for helping the Justice Department in its Swiss banking investigation, the US Court of Appeals for the D.C. Circuit said. Later, Shands sued the IRS for rejecting his claim to a cut of the larger $2.3 billion pool the agency recovered through its related Offshore Voluntary Disclosure Initiative.

Shands appealed when the US Tax Court decided ...