Practitioners representing the whistleblowing community may want to take a quick peek at Ch J Patrick J. (“Scholar Pat”) Urda’s order in Santo A. Dileo, Sr., Docket No. 3195-26W, filed 8/31/26.

Santo Sr. is pro se, so IRS wants a Rule 103 to cover any Section 6103(h)(4) disclosures they may have to make to Santo Sr. or his counsel.

Ch J Scholar Pat obliges. And here’s a preview of what IRS will accept.

Practitioners may want to drag-and-drop, and tailor appropriately, so when they need to move for a Rule 103, they can lodge something that gets a “GRANTED” stamp.