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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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