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OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: These cases are before the
Court on petitioner's motions for award of litigation and
administrative costs pursuant to section 7430 and Rule 231.
Neither party requested a hearing, and the Court concludes that a
hearing is not necessary for the proper disposition of these
motions. Rule 232(a)(3). These cases were consolidated for
purposes of trial, briefing, and opinion. Rule 141(a).
Background
The motions for administrative and litigation costs involve
petitioner's 1988 and 1989 tax years.2 In the notice of
deficiency for 1988, respondent determined a deficiency in income
tax of $26,691 and additions to tax under sections 6651(a)(1),
6653(a)(1), and 6661 in the amounts of $6,665, $1,353, and
$6,673, respectively. In the notice of deficiency for 1989,
respondent determined a deficiency in income tax of $12,399 and
an accuracy-related penalty of $2,480 under section 6662(a).
2
Petitioner also has before the Court a motion for litigation
and administrative costs in docket No. 25899-91 involving her
1986 and 1987 tax years. That case was tried, and the opinion of
the Court is reported as T.C. Memo. 1994-453. Several of the
issues litigated in petitioner's 1986 and 1987 tax case are the
same as or similar to the issues involving petitioner's 1988 tax
year. Where necessary, therefore, the Court here relies on the
findings of the Court in T.C. Memo. 1994-453 (involving tax years
1986 and 1987) as such findings relate to the merits of
petitioner's motion for 1988.
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