- 16 - her return and she would have been liable for an addition to tax for failure to file under section 6651(a) for 1986. Similarly, if these issues had been decided in respondent's favor, petitioner then would have substantially understated her tax and would have been liable for an addition to tax under section 6661 for 1986. Finally, if these issues had been decided in respondent's favor, then petitioner's liability for additions to tax for negligence under section 6653(a) for 1986 and 1987, and for substantial understatement under section 6661 for 1987, would have been increased. F. Conclusion As we have decided that respondent's position in both the administrative and Court proceedings for the years in issue was substantially justified, we need not decide (1) whether petitioner unreasonably protracted the proceedings, and (2) whether the administrative and litigation costs petitioner claims are reasonable. Petitioner's motion, therefore, will be denied. An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011