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(but not Cyndie) was liable for deficiencies, additions to tax,
and penalties as set forth below:
Addition to Tax Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) Sec. 6663
1991 $3,759 -- -- --
1992 53,289 $6,996.75 -- $18,889.13
1993 38,509 7,595.75 -- 14,440.88
1994 21,809 1,629.70 -- 3,481.50
Discussion
Section 7430(a) provides that the prevailing party may be
awarded reasonable administrative costs incurred in connection
with an administrative proceeding within the Internal Revenue
Service (IRS) and reasonable litigation costs incurred in
connection with a court proceeding. For this Court to award
reasonable administrative and litigation costs under section
7430, the moving party must satisfy several conjunctive
requirements. Specifically, the record must show, inter alia,
that:
(1) The moving party exhausted any administrative remedies
available to him or her within the IRS. See sec. 7430(b)(1).
(2) The moving party did not unreasonably protract the
administrative proceeding or the proceeding in this Court. See
sec. 7430(b)(3).
(3) The moving party is the prevailing party. See sec.
7430(a).
Respondent concedes that petitioners have met the first two
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