No, this is not about a highroller caught in a Dixieland Boondockery. This is the story of John R. Dee, Docket No. 377-20W, filed 7/17/25. John is seeking more than the 1% IRS gave him for blowing on a highroller whose escapades John ripped from the headlines and promptly tipped off IRS.
Of course, IRS knew all about it. John’s tips about the management company and vice-president of highroller’s Sub S don’t add to IRS’ $7 million takedown of highroller’s wholly-owned Sub S and his own self. John’s earlybirding does get him a 1% $71K payday.
John claims he should get more. IRS wants summary J that John should take the money and run, and gets it.
STJ Diana L. (“Sidewalks of New York”) Leyden agrees John should do the Woody Allen.
“The only dispute that petitioner raises is that the amount of the award determined by the WBO was incorrect because ‘[w]hile certain facts were aggregated from media reports, petitioner’s claim involved extensive research and analysis of a multitude of public data and produced mountains of original information and analysis in support of petitioner’s allegations.’” Order, at p. 5.
IRS ran the Reg. Section 301.7623-4(c)(2) checklist as shown at Order at pp. 2-4, and all of John’s extensive research and analysis was only a dredge of public stuff.
John does much better than most blower-packagers. He doesn’t even get sequestered.