Tax Law Updates | New Statutes, Regulations, and Rulings
July 23, 2010
Tax Court: IRS Letter of Denial of Whistleblower’s Claims Qualifies as a Determination Sufficient to Confer Jurisdiction
William Prentice Cooper, III v. Commissioner of Internal Revenue
Nos. 24178-09W, 24179-09W, 7/8/2010
In a case of first impression, the Tax Court has ruled that a letter sent by respondent Commissioner of Internal Revenue (“CIR”) to petitioner denying petitioner’s whistleblower claims constitutes a “determination” that would confer on the Tax Court jurisdiction to review denial of the claims.
By way of background, Petitioner, an attorney, submitted two Forms 211, Application for Award for Original Information, to the Internal Revenue Service (IRS) in 2008 concerning alleged violations of the Code. He alleged in the two claims that certain parties had failed to pay millions of dollars in estate and generation-skipping transfer tax.
Petitioner alleged in…
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