Opinion
4507-20W
12-15-2022
ANTHONY J. DE ANGELO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Ronald L. Buch Judge
The face page of the petition in this case asks us to review a Notice of Determination Under Section 7623 Concerning Whistleblower Action. The letter accompanying the petition states: "The Whistleblower Office has made a final decision to reject your claim for an award." This is a notice of rejection. See Treas. Reg. § 301.7623-3(b)(3).
In Li v. Commissioner, 22 F.4th 1014 (D.C. Cir. 2022), the Court of Appeals for the District of Columbia Circuit held that the Tax Court lacks subject matter jurisdiction over whistleblower cases involving rejections of claims for whistleblower awards. On October 31, 2022, the Supreme Court denied Ms. Li's petition for writ of certiorari. The Court of Appeals' judgment in the District of Columbia Circuit case is now final. Accordingly, it is
ORDERED that this case is dismissed for lack of jurisdiction.