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
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