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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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