VILLA-ARCE v. C.I.R.

No. 22-1006.

68 F.4th 1328 (2023)

Luis VILLA-ARCE, APPELLANT v. COMMISSIONER OF INTERNAL REVENUE, APPELLEE.

United States Court of Appeals, District of Columbia Circuit.

Decided May 26, 2023.


Attorney(s) appearing for the Case

Robert R. Duncan argued the cause for appellant. With him on the briefs were Matthew S. Apfel and James Podolny .

Marie E. Wicks , Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was Bruce R. Ellisen , Attorney.

Before: Pillard and Katsas, Circuit Judges, and Randolph, Senior Circuit Judge.


Luis Villa-Arce sent information to the Whistleblower Office of the Internal Revenue Service that he believed showed a company was underpaying taxes by taking unjustified deductions and using improper pricing practices. Section 7623 of the Internal Revenue Code entitles whistleblowers to a percentage of the proceeds the IRS...

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