T.C. Memo. 1997-183 UNITED STATES TAX COURT ROGER L. AND PATRICIA A. LAVALLEE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1604-95. Filed April 21, 1997. Roger L. and Patricia A. Lavallee, pro sese. James F. Kearney, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Petitioners are seeking an award of reasonable administrative costs pursuant to section 7430(f)(2)1 and Rules 270-274.2 1Sec. 7430(f)(2) provides that "A decision granting or denying (in whole or in part) an award for reasonable administrative costs under subsection (a) by the Internal Revenue Service shall be subject to appeal to the Tax Court under rules similar to the rules under section 7463 (without regard to the amount in dispute)." 2The petition for administrative costs in this case was (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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