Source document

Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (Supplemental Opinion, Docket Nos. 21276-13W, 21277-13W)

United States Tax Court · Court · 3 Aug 2016 · United States

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.

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