§41108

115- 123, § 41108(a)(2), (d), 132 Stat. 64, 158–59. The amended text does not apply because the WBO denied the OVDI claim on May 25, 2016.

115-123, § 41108(a), 132 Stat.

II, § 41108(a), 132 Stat. 64, 158. And the statute does not define the term “proceeds in dispute.” 8 [*8] approximately $180,000. No matter how we count these amounts, they all fall far short of the $2 million threshold. With respect to five of the six remaining claim numbers (2018- 012740, 2018-012741, 2018-012742, 2018-012743, and 2018-012744), the

per v. Commissioner, 136 T.C. 597, 600 (2011). In the event the whistleblower is not satisfied with the IRS’ award determination under section 7623, Congress has authorized that whistleblowers 5The Bipartisan Budget Act of 2018, Pub. L. No. 115-123, sec. 41108, 132 Stat. at 158-159, amended some of the terminology in sec. 7623, including adding a definition of “proceeds” in subsec. (c). We recently held that these amendments apply to any whistleblower claim until the WBO’s determinations can no

ds upon the Commissioner commencing an administrative or judicial action and collecting proceeds.” Petitioner contends that respondent’s “general statement of law * * * is no longer accurate based upon the amendment to Section §7623 [sic] enacted in Section 41108 of the Bipartisan Budget Act of 2018 which amended 26 USC §7623 to provide that awards are to be based upon proceeds ‘without regard to whether such proceeds are available to the Secretary.’” Fifth, petitioner lodges numerous complaints