T.C. Memo. 1996-494
UNITED STATES TAX COURT
NELLWYN A. BUCK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11766-95. Filed November 4, 1996.
Jeffrey A. Dickstein, for petitioner.
Michael J. O'Brien, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This case is before the Court
on petitioner's motion to recover administrative and litigation
costs1 pursuant to section 7430 and Rule 231.2
1 Although petitioner's motion is styled "Motion for
Litigation Costs", we are satisfied that petitioner intended to
move for an award of administrative costs as well as litigation
costs.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue; however, all references to sec. 7430 are to the Internal
Revenue Code in effect at the time that the petition was filed.
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