Whether this dispute is even ripe for review by the Supreme Court

QUESTIONS PRESENTED 1.) Whether this dispute is even ripe for review by the Supreme Court of the United States (“this Court”) when Respondent’s agency administrative record has never been filed with the U.S. Tax Court (“the Tax Court”) and is not part of the judicial record, when Respondent has refused to comply with discovery, when the Tax Court has refused to compel Respondent to comply with discovery and when no effort has been made by either Respondent or the Tax Court to remedy the taint to Respondent’s agency administrative record created by the known hostile that existed between Respondent’s whistleblower analyst and Petitioner for more than four years? 2.) Whether the Tax Court and the Court of Appeals for the District of Columbia Circuit (“the Court of Appeals”) properly ignored the clear and controlling judicial precedent identified in SEC uv. Chenery Corp., 318 U.S. 80 (1943), when conducting a judicial review of an administration determination and both lower courts accepted Respondent’s new and contradictory administrative allegations first raised during the judicial review phase? 3.) Whether the Tax Court and the Court of Appeals applied the proper standard of review when reviewing new and contradictory administrative allegations that were only first raised during the judicial review phase with no change to the underlying facts or law? li QUESTIONS PRESENTED — Continued 4.) Whether the Tax Court and the Court of Appeals properly ignored the doctrine of stare decisis, which counsels the federal judiciary to follow the holdings of previously decided cases, absent special justification, when both lower courts ignored their own controlling precedents on numerous legal issues to reach legal conclusions that conflicted with their earlier decisions? 5.) Whether the standard for subject matter jurisdiction by the Tax Court to review tax whistleblower claims under 26 U.S.C. §7623(b)(4), which states that “any determination regarding an award under paragraph (1), (2) or (3) may. . . be appealed to the Tax Court”, properly includes additional requirements created by the Court of Appeals that are not found in the broad statutory language?