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that it was.2 All section references are to the Internal Revenue
Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure. Dollar amounts
are rounded to the nearest dollar. Simpson Financial Services,
Inc., Richard H. Simpson, and Christine R. Simpson are separately
referred to as Simpson Financial, Mr. Simpson, and Mrs. Simpson,
respectively. Mr. Simpson and Mrs. Simpson are collectively
referred to as the Simpsons.
Background
We decide petitioners' motion for an award of administrative
and litigation costs on the record of the case, including
respondent's objection and the parties' affidavits and exhibits,
which are incorporated herein by this reference. Neither party
requested a hearing, and we conclude that one is not necessary.
Rule 232(a)(3). Simpson Financial's principal place of business
was Kenner, Louisiana, when it filed its petition. The Simpsons
are husband and wife. When they filed their petition, they
resided in Kenner, Louisiana.
On February 24, 1993, respondent issued 30-day letters to
petitioners, proposing deficiencies in their income taxes.
same as that taken in her notices of deficiency.
2 Based on our holding, we do not decide the other issue in
dispute; namely, whether the litigation and administrative costs
claimed in petitioners' motion filed Mar. 13, 1996, are
reasonable.
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