Opinion
26635-16W
04-17-2024
WHISTLEBLOWER 26635-16W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Richard T. Morrison, Judge.
Upon due consideration of respondent's unopposed Motion to Remand, filed April 12, 2024, it is
ORDERED that respondent's above-referenced Motion to Remand is granted, and this case is remanded to respondent's Whistleblower Office to enable the Whistleblower Office to address whether petitioner's information substantially contributed to the adjustments made to the Target Taxpayer's return for 2005 and whether there could be post-determination proceeds as defined by Treas. Reg. Section 301.7623-2(d)(5)(ii). It is further
ORDERED that, on or before July 15, 2024, the parties shall file reports reflecting the then-current status of this case. It is further
ORDERED that petitioner's November 18, 2019 Motion for Summary Judgment is denied as moot. It is further
ORDERED that petitioner's July 10, 2020 Motion to Remand is denied as moot. It is further
ORDERED that petitioner's July 10, 2020 Motion to Shift the Burden of Proof is denied as moot. It is further
ORDERED that respondent's July 10, 2020 Motion for Summary Judgment is denied as moot.