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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.
Discussion
Section 7430 provides for the recovery by a taxpayer of
certain costs incurred in connection with an administrative
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