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because of lack of substantiation, the charitable deduction had
been adjusted to the amount verified, the cost of goods sold was
allowed to the extent shown, and the Schedule C deductions were
allowed as verified.
On June 30, 1997, petitioner filed a petition with this
Court. Petitioner resided in Forestville, Maryland, at the time
her petition was filed. On August 12, 1997, respondent's answer
was filed.
In a letter dated February 5, 1998, an Appeals officer for
the Service informed petitioner that a conference had been
scheduled for February 13, 1998, for the purpose of attempting to
settle without trial the issues in her case pending before the
Court. The parties entered into a settlement stipulation, filed
on April 13, 1998, which reflected an overpayment of $600 by
petitioner for taxable year 1993. On April 14, 1998, this Court
entered a stipulated decision pursuant to the settlement
stipulation.
Petitioner thereafter filed with the Court a motion seeking
an award of litigation costs in the amount of $10,720.40.
Petitioner later increased this amount to $15,486.35 to correct a
mathematical error and to adjust for the purportedly additional
hours petitioner's attorney spent on this case to date. In
petitioner's motion for leave to amend motion for an award of
reasonable litigation costs, petitioner expressly stated that the
motion was for an award of attorney's fees and does not include
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