Girish and Nalini G. Patel - Page 4

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               Petitioner, on February 12, 1997, sent a letter to                     
          respondent giving the name of petitioner's father and telling               
          respondent to search the administrative files for information               
          petitioner had earlier provided to the IRS in Houston.                      
          Petitioner's letter contained petitioner's Social Security                  
          number, but not the Social Security number of the person                    
          petitioners claimed paid the tax on the interest income.  After             
          the filing of the petition, respondent's Appeals Office attempted           
          to contact petitioners by telephone and by letters dated June 2             
          and June 17, 1997.                                                          
               On September 17, 1997, the Clerk of the Court sent a notice            
          to the parties informing them that the case was set for trial at            
          the Trial Session beginning on December 8, 1997, in Houston,                
          Texas.  When the case was called for trial, the parties appeared            
          and were heard.  Respondent reported that a basis of settlement             
          had been reached with regard to the case and that respondent                
          conceded that there was no deficiency in income tax due from, or            
          overpayment due to, petitioners for the tax year 1994.  At that             
          time, petitioners requested an award of litigation costs.                   
               Petitioners filed a Motion for Litigation Costs in the                 
          amount of $3,000 on January 12, 1998.  Respondent’s objection to            
          petitioners’ motion was filed on April 3, 1998.  A Stipulation of           
          Settled Issues was filed by the parties on March 2, 1998.                   
               Section 7430 provides that in any court proceeding brought             
          by or against the United States in connection with the                      




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