Whistleblower award denied after target pays more tax on its own returns

Whistleblower 11099-13W v. Commissioner. Tax Court No. 11099-13W. Memo. 2026-5.

The Tax Court upheld a denial of a whistleblower award because the IRS did not collect any proceeds from an IRS action, and the taxes the company reported and paid on its own returns did not count as “collected proceeds” under §7623(b).

Holding

The IRS did not collect proceeds “as a result of” an administrative or judicial action based on the whistleblowe…