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motion to the recovery of litigation costs due to respondent’s
determination of the accuracy-related penalties. We bear in mind
the fact that section 7430 allows taxpayers to recover litigation
costs incurred in the preparation and prosecution of a motion
requesting such costs, see Han v. Commissioner, T.C. Memo. 1993-
386, and we apportion 15 percent of petitioners’ requested costs
to the accuracy-related penalties issue. We award petitioners
$1,844 in litigation costs.
We have considered all arguments in this case and, to the
extent not discussed above, find them to be irrelevant or without
merit. To reflect the foregoing,
An appropriate order will be
issued, and decision will be entered
under Rule 155.
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Last modified: May 25, 2011