Standard and scope of review of whistleblower award determinations

(a) In general Paragraph (4) of section 7623(b) is amended— (1) by striking appealed to and inserting reviewed by, and (2) by adding at the end the following: Any review by the Tax Court under the preceding sentence shall be de novo and shall be based on the administrative record established at the time of the original determination and any additional newly discovered or previously unavailable evidence.. (b) Conforming amendment The heading of paragraph (4) of section 7623(b) is amended by striking Appeal and inserting Review. (c) Effective date The amendments made by this section shall apply to petitions under section 7623(b)(4) of the Internal Revenue Code of 1986 which are pending on, or filed on or after, the date of the enactment of this Act.

(a) In general Paragraph (4) of section 7623(b) is amended— (1) by striking appealed to and inserting reviewed by, and (2) by adding at the end the following: Any review by the Tax Court under the preceding sentence shall be de novo and shall be based on the administrative record established at the time of the original determination and any additional newly discovered or previously unavailable evidence.. (b) Conforming amendment The heading of paragraph (4) of section 7623(b) is amended by striking Appeal and inserting Review. (c) Effective date The amendments made by this section shall apply to petitions under section 7623(b)(4) of the Internal Revenue Code of 1986 which are pending on, or filed on or after, the date of the enactment of this Act.