No, not a baseball story. Whistleblower 6417-20W, Docket No. 2026-89, filed 9/16/26, is the story of how someone pitching tax services and technology claims a Section 78623 whistleblower ward, which the Ogden Sunseteers negative by sowing they knew all along. Ch J Patrick J. (“Scholar Pat”) Urda, obviously relishing this opportunity to escape the role of judicial busyworker, delves deep into the administrative record to find Blower 6417 added nothing to IRS’ ongoing examinations.

“Petitioner had no inside knowledge about Target or its tax planning and was not involved in the preparation of Target’s financial or tax returns. Likewise, ‘[v]irtually all the information . . . supplied was derived from publicly available sources, such as newspaper articles, business journals, and SEC filings.’ Researching this type of public information was nothing notable, but the first stop in any transfer pricing examination….

” Although petitioner mentions discussions with an advisor and then in February 2013, Target representatives, there is less than meets the eye. The advisor with whom petitioner discussed Target’s transfer pricing did not work for Target but merely had reviewed ‘how [it] do[es] [its] allocations.’ Target’s advisor moreover did not have ‘direct access to the cost sharing calculations’ or a full picture of the various components of Target’s transfer pricing analysis. Their discussions came in connection with petitioner’s attempts to convince Target to retain petitioner’s services regarding transfer pricing compliance.” T. C. Memo. 2026-89, at p. 24. (Citation omitted).

Ch J Scholar Pat stresses in no fewer than five (count ’em, five) places in his opinion that whatever Blower 6417 got, he got as he pitched Target for their tax business and got no inside scoop.

Making a sales pitch is no route to a Section 7623 payday.