Michael Lissack

CourtUnited States Tax Court
DecidedAugust 17, 2021
Docket399-18
StatusPublished

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Bluebook
Michael Lissack, (tax 2021).

Opinion

157 T.C. No. 5

UNITED STATES TAX COURT

MICHAEL LISSACK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 399-18W. Filed August 17, 2021.

P filed Form 211, Application for Award for Original Informa- tion, claiming that T had failed to report membership fees as gross income. R initiated an examination on the basis of P’s claim. During the examination R determined that T had properly treated the mem- bership fees as nontaxable deposits but also discovered an unrelated issue--that T may have claimed an erroneous deduction. R expanded the scope of the examination to include the latter issue and ultimately disallowed the deduction, yielding a $60 million adjustment. R sub- sequently denied P’s whistleblower claim on the ground that he had not supplied any information about the erroneous deduction.

A whistleblower is eligible for an award only if R “proceeds with an[] administrative or judicial action * * * based on information” supplied by the whistleblower and collects proceeds “as a result of the action.” I.R.C. sec. 7623(b)(1). The parties have filed cross-motions for summary judgment addressed to the question whether P is entitled to an award under this standard.

Served 08/17/21 -2-

Held: Although R proceeded with an administrative action, P is not eligible for a whistleblower award because R did not collect any proceeds “as a result of the action.” See I.R.C. sec. 7623(b)(1). The examination of the erroneous deduction issue constitutes a separate administrative action that was not initiated on the basis of P’s claim. See sec. 301.7623-2(a)(2), (b)(1) and (2), Example (2), Proced. & Admin. Regs.

Held, further, the construction of I.R.C. sec. 7623(b)(1), as set forth in these regulations, is valid under Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (1984).

Scott A. Knott, Erica L. Brady-Gitlin, and Gregory S. Lynam, for petitioner.

Paul Colleran and Tara P. Volungis, for respondent.

OPINION

LAUBER, Judge: In 2009 petitioner filed a claim for a whistleblower

award under section 7623.1 He informed the Internal Revenue Service (IRS or re-

spondent) that a group of entities had failed to include in gross income millions of

dollars of membership fees. The IRS Whistleblower Office (Office) processed his

claim and referred it to a revenue agent, who initiated an examination. The reve-

1 Unless otherwise indicated, all statutory references are to the Internal Revenue Code in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. -3-

nue agent determined that the entities had properly treated the membership fees as

nontaxable deposits. But he separately discovered an unrelated issue--that the

entities had claimed an erroneous deduction--and made a $60 million adjustment

on that account. The Office denied petitioner’s claim because the adjustment was

unrelated to the information he had supplied.

Section 7623(b)(1) provides that a whistleblower is entitled to an award

only if the IRS proceeds “based on” the information he supplied and collects

proceeds “as a result of the action.” The parties have filed cross-motions for

summary judgment as to whether petitioner is entitled to an award under this

standard. Concluding that respondent has the better argument, we will grant his

motion for summary judgment and deny petitioner’s.

Background

The following facts are derived from the parties’ pleadings and motion pa-

pers, including a declaration that attached the administrative record. Petitioner

resided in Massachusetts when he filed his petition. We have jurisdiction under

section 7623(b)(4).

Petitioner filed a Form 211, Application for Award for Original Informa-

tion, which the Office received on February 6, 2009. Petitioner identified an af-

filiated group of entities (Target) that developed condominiums and offered golf -4-

and beach club memberships to condominium residents. The residents paid sub-

stantial upfront membership fees, which Target treated as nontaxable deposits in

the year received. Petitioner alleged that, in November 2008, Target changed its

refund policy such that Target acquired “complete control over” the fees received

that year. Petitioner asserted that Target was thus required to include the member-

ship fees in gross income.

The Office assigned nine claim numbers to petitioner’s case, evidently cor-

responding to the various entities comprising Target. The claim was referred to

Nora Beardsley, the Office’s senior tax analyst. Ms. Beardsley reviewed petition-

er’s claim and determined that it appeared to identify a discernible Federal tax

issue.2 See Internal Revenue Manual (IRM) pt. 25.2.2.12(1)(e) (Dec. 30, 2008).

She accordingly forwarded the case to the IRS Large Business & International

Division (LB&I), which examines “corporations and partnerships with assets

greater than $10 million.” See IRM pt. 1.1.24.1(2) (Sept. 24, 2020).

A revenue agent (RA) in LB&I reviewed petitioner’s allegations by re-

searching Target and analyzing the group’s tax returns and IRS account tran-

2 Ms. Beardsley initially informed petitioner that the Office was rejecting his claim because he submitted it before Target’s tax returns for 2008 were due. Ms. Beardsley subsequently determined that this was not a valid reason for rejection and reopened the case. -5-

scripts. In July 2011 the RA initiated a Form 11369, Confidential Evaluation

Report on Claim for Award. The RA noted that “no audit or investigation [had

been] planned” by LB&I but that the “[i]nformation submitted by the whistleblow-

er was sufficient to warrant beginning of examination.”

After examining the facts and relevant law the RA concluded that Target

“did not have unfettered right and dominion over the deposits” and thus “properly

excluded the deposits from gross income in the year received.” Finding that Tar-

get properly “deferred the recognition of the deposits,” the RA “propose[d] no ad-

justment related to the membership deposits issue.”

The RA returned Form 11369 to the Office on August 19, 2011. A few

months later he prepared a report for the Office, stating that “the whistleblower

claim was fully investigated” and “no change was proposed.” But he indicated

that he had identified another issue, namely a deduction in excess of $60 million

that Target had claimed “for intercompany bad debt.” See sec. 166. He stated that

the bad debt issue would take some time to examine but that it was “unrelated to

the subject of the whistleblower claims.” Ms. Beardsley decided to keep the case

open until the RA finished his further investigation.

In 2013 the RA completed his examination, and the IRS issued Target no-

tices of proposed adjustment. The RA disallowed the $60 million bad debt deduc- -6-

tion and made a number of other (relatively minor) adjustments, all for tax year

2009. These other adjustments affected four entities within Target and included

such items as salaries and wages, taxes and licenses, and partnership losses.

The RA forwarded to Ms. Beardsley the entire case file, including the

Forms 4549, Income Tax Examination Changes, and Forms 886-A, Explanation of

Items, that had been issued to Target. These documents showed that none of the

adjustments had anything to do with the membership deposits issue. When Ms.

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Michael Lissack, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-lissack-tax-2021.