- 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.
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Last modified: May 25, 2011