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COOPER v. COMMISSIONER

Nos. 24178-09W, 24179-09W.

135 T.C. 70 (2010)

WILLIAM PRENTICE COOPER, III, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 8, 2010.

Attorney(s) appearing for the Case

Joseph G. Giannola and Robert J. Mauceri, for petitioner.

Holly H. Styles, and Alex Shlivko, for respondent.

OPINION

KROUPA, Judge.

These cases are before the Court on respondent's motions to dismiss for lack of jurisdiction. We decide for the first time whether a letter sent by respondent to petitioner denying petitioner's whistleblower claims constitutes a "determination" within the meaning of section 7623(b)(4)1 that would confer on us jurisdiction to review denial of the claims. We...

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