Filed January 10, 2025

No. 21-1268

MICHAEL LISSACK, APPELLANT

v.

COMMISSIONER OF INTERNAL REVENUE, APPELLEE

On Remand from the Supreme Court of the United States

Erica L. Brady-Gitlin argued the cause for appellant. With her on the briefs were Gregory S. Lynam and Scott A. Knott.

Brian C. Wille and Usman Mohammad were on the brief for amicus curiae Whistleblower 1109-13W in support of appellant.

Dean Zerbe and Stephen M. Kohn were on the brief for amicus curiae National Whistleblower Center in support of appellant.

Julie Ciamporcero Avetta, Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was Bruce R. Ellisen, Attorney. 2 Before: PILLARD and KATSAS, Circuit Judges, and RANDOLPH, Senior Circuit Judge.

Opinion for the Court filed by Circuit Judge PILLARD.

PILLARD, Circuit Judge: Section 7623 of the Internal Revenue Code authorizes the IRS to pay awards to whistleblowers who identify underpayment of taxes or violations of intern