Cheryl A. Wolf - Page 4




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          violations of Federal law at the USMMA and making vague claims              
          for entitlement to unspecified tax credits for 1996.                        
               During a conference call held with this Court and the                  
          parties herein on April 4, 2007, and at a subsequent hearing,               
          petitioner clarified that the real and only relief she seeks                
          herein is a reward relating to the information that petitioner              
          provided to respondent about alleged corruption at the USMMA.               

                                     Discussion                                       
               Prior to December 20, 2006, section 7623 provided that                 
          respondent may give to individuals who provide information                  
          relating to Federal Tax Code violations monetary rewards payable            
          from the proceeds of tax revenue collected as a result of such              
          information.  We, however, had no jurisdiction to review                    
          respondent’s discretion in giving or denying such rewards.                  
               As part of the Tax Relief and Health Care Act of 2006                  
          (TRHCA), Pub. L. 109-432, div. A, sec. 406(a)(1)(D), 120 Stat.              
          2589, Congress amended section 7623 and provided jurisdiction for           
          this Court to review respondent’s denial of claims for rewards as           
          a result of information provided to respondent relating to                  
          Federal Tax Code violations.                                                
               Newly enacted section 7623(b)(4), however, is made effective           
          only for information provided to respondent on or after December            
          20, 2006, id. sec. 406(d), 120 Stat. 2960, and it provides the              








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