A whistleblower was cooperating with the Department of Justice and the IRS in connection with an ongoing investigation of two Swiss bankers.  When the investigation led to incriminating information about a substantial penalty paid by a taxpayer, the whistleblower filed a claim with the IRS Whistleblower Office.  When counsel for the whistleblower inquired as to the status of the claim, an Office representative responded that the claim was still open but also sent along an IRS memorandum showing that the type of penalty paid by the taxpayer could not be the basis of an award.  The U.S. Tax Court rejected the whistleblower’s argument that this constituted a final determination from which he could appeal to the court.  Thus, the court dismissed the whistleblower’s appeal for lack of jurisdiction. Whistleblower 22231-12W v. Comm’r, T.C. Memo. 2014-157 (U.S. Tax Ct. Aug. 4, 2014).