- 7 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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