1973 North Rulon Road in The City of the Golden Spike is a perfect site for a statue of Mandy Mobley Li, whose perfect own-goal lightened forever the burdens of the Ogden Sunseteers, and forever immunized said Sunseteers from any form of judicial scrutiny.

Thomas Shands, 160 T. C. 5, filed 3/8/23 (a very special day in our family’s calendar), delivered a Swiss bankster, an architect of hidey-holes for tax evaders, into the hands of the Federales. Tom claims the highly-publicized bust caused numerous hidey-holeowners to come out with their hands up, confess their sins and join OVDI II. Tom wore a wire for IRS CI and got Renzo Gadola, leading skulldugger, to spill the legumes thereinto. The US Attorney at Renzo’s sentencing told everyone that Tom was the man who made the case.

Of course, John (“Hoppin’ John”) Hinman’s crew says the info Tom gave IRS didn’t involve specific taxpayers, and the fact that a bunch Swiss squirrels (hi, Judge Holmes) fessed up isn’t a “related action” within the meaning of Reg.  Section 301.7623-2(c)(1).

Judge Travis A. (“Tag”) Greaves agrees.

Section 7623(b)(5)(A) refers to money realized from an action or proceeding “against a taxpayer.” Renzo was none of the above. “We likewise reject petitioner’s argument that inherently voluntary participation in OVDI by a taxpayer constitutes an administrative or judicial action by the IRS. This Court has recognized that a taxpayer’s voluntary compliance absent an examination entailed no administrative action, even if IRS scrutiny prompted the taxpayer’s compliance.” 160 T. C. 5, at p. 9. (Citation omitted). (Emphasis by the Court).

No longer does Lacey afford Tax Court a backdoor to oversee whether the Sunseteers are taking serious looks at Forms 211. All the Sunseteers need do is claim “no dough, no award.”

And of course the Li decision debars Tax Court from looking behind any rejection or denial of a whistleblower’s claim. Anyway, there’s no difference between rejection and denial. Bottom line is blower gets nothing, Treasury gets billions.

So, blowers, virtue is definitely its own reward.