Source document
Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (Supplemental Opinion, Docket Nos. 21276-13W, 21277-13W)
Has everything in it been taken?
CompleteReviewed 8 Oct 2026
Reviewed. Everything in it that belongs in the tables has been taken.
What the document holds
Tax Court supplemental opinion, Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (3 Aug 2016, 33 pp.): husband and wife whistleblowers; earlier opinion (144 T.C. 290, 2015) held their claims timely; parties agreed a 24% award; the taxpayer paid $74,131,694 (restitution $20,000,001, fine $22,050,000, forfeitures $15,821,000 and $16,260,693); held that criminal fines and civil forfeitures are collected proceeds; award $17,791,607. Also discusses the 1867 origin of 7623(a), the 1996 amendment, IRM guidance and Whistleblower 22716-13W (146 T.C., FBAR penalties and the $2 million threshold). Already recorded: the award case (24%, $74,131,694), the 22716-13W denial case and the 2016 holding event; 1867 and 1996 events exist from other sources. Added two legal events (2015 Form 211 holding; 2016 FBAR threshold holding) and suggested corrections: award amount $17,791,607 on the existing case (the old note says it is not stated, but it is on p. 33), and a note update on the 22716-13W case.
What it supports
5 rows on this site come from this document. Each one opens with the page and the exact words.
Cases and awards (2)
- Whistleblower 22716-13W v. Commissioner (146 T.C.): the information led to a small tax restitution and FBAR civil penalties over $2 million; the IRS denied the claim, saying FBAR penalties do not count toward the $2 million threshold.2016DeniedUnited States · IRS Whistleblower Program (Whistleblower Office), 26 U.S.C. § 7623
- A husband and wife reported a taxpayer (a firm that later pleaded guilty to conspiracy) and were rejected as untimely; the Tax Court reversed in 2015, the parties agreed a 24% award, and in 2016 the Court held that the criminal fine and civil forfeitures, not just tax restitution, count as collected proceeds.USD 17,791,6073 Aug 2016 · Money collected USD 74,131,694AwardedUnited States · IRS Whistleblower Program (Whistleblower Office), 26 U.S.C. § 7623
Timeline (3)
- Tax Court: criminal fines and forfeitures are collected proceeds3 Aug 2016LegalUnited States · IRS Whistleblower Program (Whistleblower Office), 26 U.S.C. § 7623
- Tax Court: FBAR penalties do not count toward the $2 million threshold (Whistleblower 22716-13W, 146 T.C.)14 Mar 2016LegalUnited States · IRS Whistleblower Program (Whistleblower Office), 26 U.S.C. § 7623
- Tax Court: Form 211 need not come first (Whistleblower 21276-13W, 144 T.C. 290)2015LegalUnited States · IRS Whistleblower Program (Whistleblower Office), 26 U.S.C. § 7623
About the document
What it covers Tax Court holds criminal fines and civil forfeitures are collected proceeds; 24% award agreed; also describes Whistleblower 22716-13W (FBAR penalties not counted toward the $2 million threshold).
Notes Official Tax Court opinion; copy obtained from a law-firm website (Kohn, Kohn & Colapinto) because the Tax Court site has no static URL. Whistleblowers anonymous by court order.
Source id usa-ustc-wb21276-13w-2016 · accessed 3 Oct 2026