James L. Ball - Page 7

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            petitioner's 1984 return.  On July 15, 1991, respondent abated                              
            petitioner's 1985 overassessment, additions to tax, and accrued                             
            interest, but did not abate assessment of tax for amounts shown                             
            on petitioner's 1985 return.  On July 22, 1991, respondent abated                           
            the addition to tax for failure to timely pay and interest for                              
            petitioner's 1986 taxable year.                                                             
            5.    Petitioner's Claim for an Award of Administrative Costs                               
                  On August 29, 1991, petitioner filed a claim for an award                             
            of administrative costs with respondent.  Respondent denied the                             
            claim on October 21, 1991.  Petitioner then filed the petition                              
            for administrative costs.                                                                   
                                               OPINION                                                  
            1.    Positions of the Parties                                                              
                  Petitioner contends that he is entitled to an award of                                
            reasonable administrative costs under section 7430.  The                                    
            Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L.                            
            100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746, amended section                           
            7430 to allow the recovery of costs incurred in administrative                              
            proceedings.  See also H. Conf. Rept. 100-1104, at 224-226                                  
            (1988), 1988-3 C.B. 473, 714-716.  Section 7430 provides in                                 
            pertinent part:                                                                             










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