Jeffrey L. Beecroft and Carol Larkin-Beecroft - Page 2

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                    section 7430 and Rule 231.1  Respondent issued petitioners a                                                                                           
                    notice of deficiency reflecting her determination that they were                                                                                       
                    liable for a $14,939 deficiency in their 1993 Federal income tax                                                                                       
                    and a $2,988 penalty under section 6662(a).  Petitioners                                                                                               
                    petitioned the Court to redetermine respondent's determination.                                                                                        
                              Before trial, the parties settled all issues raised in the                                                                                   
                    notice of deficiency.  The parties agree that the 1993 deficiency                                                                                      
                    is $7,539 and that the penalty is $466.  We must decide whether                                                                                        
                    petitioners are entitled to any of their claimed administrative                                                                                        
                    and litigation costs.  We conclude they are not.  Section                                                                                              
                    references are to the Internal Revenue Code.  Rule references are                                                                                      
                    to the Tax Court Rules of Practice and Procedure.  Dollar amounts                                                                                      
                    are rounded to the nearest dollar.                                                                                                                     
                                                                           Background                                                                                      
                              We decide petitioners' motion based on the record, including                                                                                 
                    respondent's objection and the parties' affidavits, declaration,                                                                                       
                    and exhibits.  Neither party requested a hearing, and we conclude                                                                                      
                    that one is not necessary.  Rule 232(a)(3).  Petitioners are                                                                                           
                    husband and wife, and they resided in Altadina, California, at                                                                                         
                    the time of their petition.  They filed a 1993 Form 1040, U.S.                                                                                         



                              1 Although petitioners' motion mentions only litigation                                                                                      
                    costs, the motion refers to costs that were incurred prior to the                                                                                      
                    notice of deficiency (i.e., administrative costs).  We consider                                                                                        
                    petitioners' motion to be a motion for both administrative and                                                                                         
                    litigation costs.                                                                                                                                      




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