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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.
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