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 thePage: Previous 1 2 3 4 5 6 Next
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