Opinion
36014-21W
03-17-2023
MARIE CLAUDIA ESTORGE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge.
This whistleblower case is on the calendar of the Court's April 3, 2023 trial session for San Francisco, California. On March 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent's motion is based on his representation that the IRS did not take any action regarding the target taxpayer and, as such, did not collect any proceeds based on the information petitioner provided.
On March 13, petitioner filed an Objection to the Motion to Dismiss for Lack of Jurisdiction. In her Objection, petitioner disputes respondent's representations. She alleges the IRS examined the target taxpayer and that the IRS collected proceeds as a result of the exam. To resolve this factual dispute, i.e., whether the IRS proceeded to examine the target taxpayer and collected proceeds, the Court will hold a hearing on respondent's Motion to Dismiss for Lack of Jurisdiction.
On March 15, respondent filed a Reference List of Redacted Information to Respondent's Motion to Dismiss for Lack of Jurisdiction. We will seal it.
Accordingly, it is
ORDERED that respondent's Reference List of Redacted Information to Respondent's Motion to Dismiss for Lack of Jurisdiction, filed March 15, 2023, is sealed from public view and shall not be inspected by any person or entity not a party to this case, except by an Order of the Court. It is further
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed March 13, 2023, is set for hearing at the calendar call of the aforementioned session of the Court, at 10:00 AM (PT).
This Order constitutes official notice to the parties.