Francesca Cappucci - Page 3

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          1992 income tax return.  Petitioner was represented by an                   
          accountant during the examinations.  On January 26, 1996,                   
          respondent mailed a notice of deficiency to petitioner, and no              
          petition was filed with this Court.  However, petitioner did seek           
          respondent’s reconsideration of the audit, which began on or                
          about February 2, 1996, and on or about April 4, 1996, respondent           
          determined that the income tax deficiencies for 1992 and 1993               
          should be reduced.  Dissatisfied, petitioner sought another                 
          reconsideration and on or about August 5, 1998, respondent                  
          determined that petitioner’s income tax deficiencies for 1992 and           
          1993 should be further reduced.                                             
               Thereafter, on or about November 21, 1998, petitioner                  
          submitted a claim for the accounting fees she incurred.                     
          Respondent determined that under section 7430(c)(2), petitioner             
          was entitled to costs (accounting fees) incurred for services of            
          a qualified representative only after the issuance of the notice            
          of deficiency issued January 26, 1996.  Based on the accountant’s           
          invoices to petitioner, respondent determined that petitioner was           
          entitled to $2,389 of costs attributable to the work performed              
          after the issuance of the notice of deficiency.                             
               Section 7430 provides for the recovery by a taxpayer of                
          certain costs incurred in connection with an administrative                 

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