- 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