Donald Del Grande, for petitioner. Elaine L. Sierra, for respondent. SUPPLEMENTAL MEMORANDUM OPINION NIMS, Judge: This matter is before the Court on petitioner's Motion for Litigation and Administrative Costs (motion for costs) filed pursuant to Rule 231 and section 7430 on April 26, 1996. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to sections of the Internal Revenue Code in effect during 1989 and 1990. The merits of the underlying case were decided in National Industrial Investors, Inc. v. Commissioner, T.C. Memo. 1996-151, filed March 26, 1996, and to the extent necessary for the disposition of this motion, the facts and holdings in T.C. Memo. 1996-151 are incorporated herein by this reference. We shall repeat the facts as necessary to clarify the following discussion. Respondent issued a statutory notice of deficiency on September 16, 1993. A petition was filed on November 22, 1993. At that time, petitioner (NII), a California corporation, had its principal office at 956 Jackling Drive, Hillsborough, California 94010. On January 18, 1994, respondent filed an answer to the petition, which she subsequently amended twice. The trial took place on December 6, 1994 at San Francisco, California, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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