Miriam Lawrence - Page 2

                                                 - 2 -                                                    
            of section 7443A(b)(4) and Rules 180, 181 and 183.1  The Court                                
            agrees with and adopts the Special Trial Judge's opinion, which                               
            is set forth below.                                                                           
                               OPINION OF THE SPECIAL TRIAL JUDGE                                         
                  CARLUZZO, Special Trial Judge:  These consolidated cases are                            
            before the Court on petitioners' motions for awards of reasonable                             
            administrative and litigation costs, pursuant to section 7430.                                
                  A hearing was conducted on petitioners' motions in Houston,                             
            Texas.  The following witnesses testified at the hearing:  Miriam                             
            Lawrence, petitioner in docket No. 4263-92; Alfonso Red, the                                  
            revenue agent who conducted the relevant examinations; Sharon L.                              
            Haddad, a certified public accountant retained by petitioners                                 
            after the cases were docketed; and Gene Hill, the Appeals officer                             
            responsible for settling the cases.  In addition, petitioners'                                
            attorneys in these cases testified with respect to the extent and                             
            value of the services they rendered.  See Rule 201(a); rule                                   
            3.7(a)(2), Model Rules of Professional Conduct of the American                                
            Bar Association.                                                                              


            1Unless otherwise indicated, section references are to the                                    
            Internal Revenue Code as amended and in effect for the relevant                               
            period.  References to sec. 7430 are to the version in effect as                              
            amended by sec. 6239(d) of the Technical and Miscellaneous                                    
            Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3743.  Unless                                 
            otherwise indicated, all Rule references are to the Tax Court                                 
            Rules of Practice and Procedure.                                                              







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011