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adopts the opinion of the Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: These cases are before the
Court on petitioner’s motion for an award of reasonable
litigation costs under section 7430 and Rules 230 through 233.
Respondent determined deficiencies in, and additions to,
petitioner’s Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1992 $46,172 $11,543 $9,234
1993 28,796 7,199 5,759
1994 73,332 –- 14,666
After these cases were docketed, the parties filed a
stipulation of settled issues that disposed of all adjustments
without trial. Thereafter, petitioner filed motions for
litigation costs and respondent filed objections to petitioner’s
motions. Neither party has requested a hearing, and the Court
concludes that a hearing is unnecessary for the proper
disposition of these motions. See Rule 232(a)(2).
These related cases have been consolidated for the purpose
of considering petitioner’s motions. At the time the petitions
were filed, the petitioner resided in Beijing, People’s Republic
of China.
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