- 3 - 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. Discussion Section 7430 provides for the recovery by a taxpayer of certain costs incurred in connection with an administrativePage: Previous 1 2 3 4 5 6 7 Next
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