- 7 - to section 7430. Minahan v. Commissioner, 88 T.C. 492 (1987); Renner v. Commissioner, T.C. Memo. 1994-372. Petitioners contend that they have substantially prevailed with respect to the amounts in controversy and on the most significant issue in these cases. They further contend that they have met the net worth requirements of 28 U.S.C., sec. 2412(d)(2)(B), that they have exhausted the administrative proceedings available to them within the Internal Revenue Service, and that they have not unreasonably protracted the administrative or court proceedings. They also argue that the costs claimed are reasonable. Respondent denies that petitioners have substantially prevailed with respect to the amounts in controversy and on the most significant issue in this case. Respondent admits that petitioner, Darl N. Miller, meets the net worth requirements but denies that petitioner Bonnie S. Miller has shown that she meets the net worth requirements. Respondent alleges that because petitioners failed to provide relevant information to the examining agent so that a 30-day letter could be issued, petitioners failed to exhaust their administrative remedies. Respondent further alleges that by failing to submit relevant information requested by the examining agent at the administrative level, before the issuance of the statutory notice of deficiency, petitioners unreasonably protracted the proceedings in this case.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011