- 11 - scheduled date, and during his meeting with Appeals Officer Whittle on June 29, 1994, Mr. Conner explained that petitioners were claiming additional amounts of Schedule C deductions. Appeals Officer Whittle originally believed that the period of limitations was no longer open for 1985 and 1987.11 Nevertheless, despite finding that petitioners had a "weak case", Appeals Officer Whittle ultimately agreed with Mr. Conner that petitioners should be considered to have made an informal claim for refund for which the period of limitations had not run and that petitioners' claimed Schedule C deductions should be allowed. Petitioners then filed a claim with respondent to recover the administrative costs incurred in connection with their case. In a letter dated December 14, 1994, respondent denied petitioners' claim for such costs. On January 26, 1995, petitioners filed with the Court a petition for administrative costs pursuant to section 7430(f)(2). The petition stated that respondent had denied petitioners' claim for $9,311.12 of administrative costs. The petition also stated that petitioners were now claiming $13,586.12 of administrative costs. 11Since petitioners' 1986 year involved only a negligible deficiency under the terms of the settlement agreement, the parties did not discuss whether the period of limitations remained open with respect to that year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011