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SMITH v. COMMISSIONER

Docket No. 25605-15W.

148 T.C. 449 (2017)

148 T.C. No. 21

IAN D. SMITH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 7, 2017.

Attorney(s) appearing for the Case

Thomas C. Pliske and Shine Lin, for petitioner.

Richard L. Hatfield, for respondent.

OPINION

This whistleblower award case, brought pursuant to section 7623(b)(4),1 is before the Court on the parties' cross-motions for summary judgment. The seminal legal issue, one of first impression, concerns the interpretation of the phrase "amounts in dispute" in section 7623(b)(5)(B) for...

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