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casualty loss of $600 resulting from the theft of petitioner's
tools. Based on these figures, computational adjustments were
made with regard to petitioner's self-employment tax. Respondent
conceded that petitioner was not liable for the additions to tax
under sections 6651(a)(1) and 6654(a). The revised tax liability
as a result of the settlement was $598. Petitioner's withholding
from 1992 of $351 coupled with his overpayment from the 1994 tax
year of $953 (which was being held by respondent for petitioner's
1992 tax liability) resulted in $1,304 total payments for 1992,
thereby creating an overpayment for that year in the amount of
$706.
On August 20, 1996, the parties filed a stipulation with the
Court reflecting, for the 1992 tax year, the settlement above
described. On August 21, 1996, pursuant to the foregoing
stipulation, this Court entered an agreed decision in this case
that reflected the parties' settlement.
Thereafter, on October 3, 1996, petitioner filed his motion
for administrative and litigation costs (motion), seeking a total
of $10,307.65 in "reasonable litigation costs"4 plus additional
attorneys' fees to be incurred in prosecution of the motion.
4 The $10,307.65 in "litigation costs" consisted of a filing
fee of $60, attorneys' fees and "related costs incurred in
preparing the Tax Court petition" of $10,176.25, and
"reproduction charges" of $71.40.
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