Francesca Cappucci - Page 5

                                        - 5 -                                         
          humiliating and arduous experience for * * * [her] * * * and                
          [her] husband.”  Petitioner also points out that the proposed               
          deficiencies started at $1,727 for 1992 and $9,550 for 1993 and             
          ended in agreed amounts of zero for 1992 and $315 for 1993.  In             
          that regard, however, respondent does not question whether                  
          petitioner is entitled to administrative costs.  Respondent                 
          agrees that petitioner is entitled to such costs, but                       
          only to the amount incurred from the time of the issuance of the            
          notice of deficiency.2                                                      
               Petitioner contends that sections 301.7430-2(a) and (b) and            
          301.7430-3(a), Proced. & Admin. Regs., provide a basis for                  
          allowance of the costs (accountant’s fees) that respondent has              
          declined to permit.  Petitioner contends that those procedural              
          regulations provide the Court with authority to grant reasonable            
          costs to petitioner, including the amount that was incurred prior           
          to respondent’s issuance of the notice of deficiency.                       
               Section 301.7430-2(a) and (b), Proced. & Admin. Regs., sets            
          forth the requirements and procedures for recovery of reasonable            
          administrative costs.  In particular, section 301.7430-2(a),                
          Proced. & Admin. Regs., is introductory and generally describes             
          the contents of the regulation.                                             

               2 There is no mention here of notice’s of decision being               
          issued by the Appeals Office.                                               

Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011