- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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