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Estorge v. Comm'r of Internal Revenue

United States Tax Court
Mar 17, 2023
No. 36014-21W (U.S.T.C. Mar. 17, 2023)

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.


Summaries of

Estorge v. Comm'r of Internal Revenue

United States Tax Court
Mar 17, 2023
No. 36014-21W (U.S.T.C. Mar. 17, 2023)
Case details for

Estorge v. Comm'r of Internal Revenue

Case Details

Full title:MARIE CLAUDIA ESTORGE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Mar 17, 2023

Citations

No. 36014-21W (U.S.T.C. Mar. 17, 2023)