Maggie Management Company - Page 11

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          Stipulation of Settled Issues resulted in "no-change" for                   
          petitioner as to the Ohanesian-related items.                               
                                     Discussion                                       
               We must decide whether petitioner is entitled to reasonable            
          litigation and administrative costs pursuant to section 7430.               
               Section 7430(a) provides that the prevailing party in any              
          administrative or court proceeding may be awarded a judgment for            
          (1) reasonable administrative costs incurred in connection with             
          such administrative proceeding within the IRS, and (2) reasonable           
          litigation costs incurred in connection with such court                     
          proceeding.                                                                 
               Congress has enacted and amended several versions of section           
          7430.  As originally enacted by the Tax Equity and Fiscal                   
          Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 292(a),            
          96 Stat. 324, 572, section 7430 was applicable to "civil actions            
          or proceedings commenced after February 28, 1983."  TEFRA sec.              
          292(e)(1), 96 Stat. 574.                                                    
               In 1986 and 1988, Congress extensively amended section 7430.           
          The amendments enacted by the Tax Reform Act of 1986 (TRA 1986),            
          Pub. L. 99-514, sec. 1551, 100 Stat. 2085, 2752-2753, generally             
          apply to "civil actions or proceedings commenced after December             
          31, 1985."  TRA 1986 sec. 1551(h)(1), 100 Stat. 2753.  The                  
          amendments enacted by the Technical and Miscellaneous Revenue Act           
          of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342,             
          3743-3746, generally apply to "proceedings commencing after                 




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