Thomas J. Mitchell and Janice M. Mitchell - Page 7

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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