4 deductions for contributions to individual defined benefit pension plans. Many of the issues raised in petitioner's Motion for Award of Reasonable Litigation Costs were answered by this Court in Price v. Commissioner, 102 T.C. 660, 662-665 (1994), affd. without published opinion sub nom. TSA/Stanford Associates, Inc. v. Commissioner, 77 F.3d 490 (9th Cir. 1996). There is no need to repeat that discussion. The statutory notice of deficiency in this case was issued by respondent on July 22, 1991. The petition was filed on September 30, 1991. In June of 1995, respondent made a full concession of the underlying actuarial issues. A decision of no deficiency in income tax and no additions to tax was signed by petitioner's counsel on June 29, 1995, and by respondent's counsel on July 13, 1995, and was filed with this Court as a Settlement Stipulation on July 18, 1995. During this intervening period prior to respondent's concession, the following cases were decided by this Court in favor of the taxpayers and were affirmed by the Courts of Appeals for the Fifth, Second, and Ninth Circuits: Vinson & Elkins v. Commissioner, 99 T.C. 9 (1992), affd. 7 F.3d 1235 (5th Cir. 1993); Wachtell, Lipton, Rosen & Katz v. Commissioner, T.C. Memo. 1992-392, affd. 26 F.3d 291 (2d Cir. 1994); and Citrus Valley Estates v. Commissioner, 99 T.C. 379 (1992), affd. in part and remanded in part 49 F.3d 1410 (9th Cir. 1995). These werePage: Previous 1 2 3 4 5 6 7 8 Next
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