Carlton M. Smith (Cardozo) has published Friedland: Did the Tax Court Blow its Whistleblower Jurisdiction?, 131 Tax Notes 843 (May 23, 2011). Here is the abstract:
This article analyzes Friedland [T.C. Memo. 2011-90 (Apr. 25, 2011)], a recent Tax Court memorandum opinion, and concludes that in light of recent Supreme Court opinions, the Tax Court was wrong to hold that the 30-day period to file a petition in a whistleblower award action cannot be equitably tolled.
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