John R. Dee

Summary

The Court held that it had jurisdiction because the whistleblower's information was forwarded to an examination team while the target's examination remained open under the applicable IRS definition of a closed case. It declined to complete or supplement the administrative record because the petitioner's proposed materials were neither shown to have been before the agency nor within an exception permitting extra-record evidence. On the merits, the Court held that the Whistleblower Office did not abuse its discretion in denying an award because the IRS had independently examined and resolved the identified issues before receiving the information.