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relevant period. Rule references are to the Tax Court Rules of
Practice and Procedure.
This case is before the Court on petitioners’ motion for
litigation and administrative costs pursuant to section 74301 and
Rule 231.
In a notice of deficiency issued on February 29, 1996,
respondent determined deficiencies in petitioners’ 1990, 1992,
and 1994 Federal income taxes in the amounts of $307, $818, and
$1,215, respectively.
The petition was filed on May 31, 1996, and on July 26,
1996, respondent's answer was filed. On November 27, 1996, a
stipulated decision was entered in which the parties agreed there
were no deficiencies in Federal income taxes for any of the years
in issue. Petitioners thereafter filed the motion here under
consideration seeking an award of litigation and administrative
costs in the amount of $7,775.81 (of which $4,006.39 is
attributable to their own time). The stipulated decision
was vacated and filed as a Stipulation of Settled Issues on
December 16, 1996. Respondent's response to the motion was
1 References to sec. 7430 are to that section as amended by
sec. 1551 of the Tax Reform Act of 1986, Pub. L. 99-514, 100
Stat. 2085, 2752 (effective for proceedings commenced after Dec.
31, 1985) and by sec. 6239(a) of the Technical and Miscellaneous
Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3743
(effective with respect to proceedings commenced after Nov. 10,
1988).
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