- 2 -
under Rule 161 (motion for reconsideration) and petitioners'
motion to vacate decision under Rule 162 and vacate order dated
April 16, 1999 (motion to vacate).1
On January 22, 1999, petitioners filed a motion for award of
litigation and administrative costs and attorney's fees
associated with Johnson v. Commissioner, T.C. Memo. 1998-448.
Attached to this motion was a net worth schedule. On February
16, 1999, respondent filed an objection to petitioners' motion
for award of litigation and administrative costs and attorney's
fees. On March 3, 1999, petitioners filed a motion for leave to
file a reply to objection to motion for award of reasonable
litigation costs (motion to file reply #1). On March 23, 1999,
respondent filed a notice of no objection. On March 25, 1999,
the Court granted petitioners' motion to file reply #1 and filed
petitioners' reply to objection to motion for award of reasonable
litigation costs (reply #1). Attached to reply #1 was a second
net worth schedule. On April 12, 1999, petitioners filed a
statement of errata. Attached to the statement of errata was a
third net worth schedule.
On April 16, 1999, the Court issued an opinion, Johnson v.
Commissioner, T.C. Memo. 1999-127 (Johnson II), in which we held
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
year in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011