4
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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