I. Whether the IRS can deprive the United States Tax Court of subject matter jurisdiction to review the IRS's denial of a mandatory whistleblower award under § 7623(b)(1) by claiming it took no action?

II. Whether the IRS can deny a mandatory whistleblower award under § 7623(b)(1) by claiming it took no action, even when the undisputed facts demonstrate that the IRS did take action?

Whether the IRS can deprive the United States Tax Court of subject matter jurisdiction by claiming it took no action on a whistleblower award and deny a mandatory award under § 7623(b)(1) despite evidence of action taken