Simpson Financial Services, Inc. - Page 3

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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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