122 T.C. No. 3
UNITED STATES TAX COURT
FLORIDA COUNTRY CLUBS, INC., A FLORIDA CORPORATION, SUNCOAST
COUNTRY CLUBS, INC., A FLORIDA CORPORATION, DEBORAH A. HAMILTON,
AND JAMES R. MIKES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9160-02. Filed February 3, 2004.
Petitioners (Ps), two S corporations and two
shareholders of those corporations, received letters of
proposed deficiency with respect to their 1993 and 1994
Federal income tax returns, which allowed Ps an
opportunity for administrative review in Respondent’s
(R) Appeals Office. After Ps protested the proposed
deficiencies with the Appeals Office, the parties
settled without R’s issuing either an Appeals Office
notice of decision or a notice of deficiency.
Ps filed a petition with this Court under sec.
7430(f), I.R.C., and Rule 271, Tax Court Rules of
Practice and Procedure, for reasonable administrative
costs. R moved for a summary judgment that Ps are not
entitled to an award of administrative costs as a
matter of law.
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