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“Amount in Dispute” Was Liability IRS Proposed After Examination Based on Whistleblower Claim (Smith, TC)

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CCH Tax Day Report In a case of first impression, the Tax Court has determined that the “amount in dispute” for purposes of a whistleblower award was the total liability the IRS proposed with respect to an examination commenced using the whistleblower’s information, not just the “collected proceeds” attributable to the whistleblower’s information or specific […]

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