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OPINION
SWIFT, Judge: This case is before us under section 7430 on
petitioners’ motion for litigation costs. Respondent determined
a deficiency of $728 in petitioners’ 2001 Federal income tax,
which determination respondent has conceded.
Respondent agrees that his position in his notice of
deficiency was not substantially justified and that petitioners
are to be regarded herein as the prevailing party for purposes of
the instant motion for litigation costs. Also, respondent has
conceded that petitioners are entitled to recover $95.06 in
litigation costs consisting of the $60 Court filing fee and
$35.06 in postage and delivery costs.
The primary issues for decision are whether the pro se
petitioners herein are entitled to recover as litigation costs:
(1) Amounts representing the value of their research time and
(2) additional out-of-pocket postage and delivery costs and out-
of-pocket mileage costs and parking fees incurred by petitioner1
to attend the Court hearing in this matter.
Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
1 All references to petitioner in the singular are to
petitioner John M. Dunaway.
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Last modified: May 25, 2011