Whether threshold rejections of whistleblower award requests are immune from the judicial review process established through the Administrative Procedure Act

QUESTIONS PRESENTED a Section 704 of the Administrative Procedure Act subjects final agency actions to mandatory judicial , review if no other adequate remedy exists in any court. When Congress enacts a specific remedy where . previous remedies were tenuous, the remedy provided is generally regarded as exclusive. The Tax Relief and Health Care Act of 2006 provides jurisdiction for the. ‘ United States Tax Court to review the denial of whistleblower award applications. ; The questions presented are: 1. Whether threshold rejections of whistleblower : award requests are immune from the judicial , review process established through . the Administrative Procedure Act 2. Whether 26 U.S.C. § 7623 grants jurisdiction to the United States Tax Court to review rejections made under § 7623(a) : 3. Whether the Whistleblower Office of the Internal . Revenue Service may avoid its statutory and | regulatory responsibilities by rejecting claims for award . pe : . 1 . | RELATED CASES : Li v. Comm’r, No. 5070-19W, U.S. Tax Court. Judgment entered April 6, 2020. : Liv. Comm ’r, No. 20-1245, US. Court of Appeals for the.,.District of Columbia Circuit. Judgment . entered January 11, 2022. Denial of motion for panel rehearing and rehearing en banc entered March 18,. : 2022. . a . |