- 7 - provisions of section 7430(c)(2)(B) limiting administrative costs to those incurred after a particular event (in this case the mailing of the notice of deficiency). We also note that respondent is in agreement that petitioner is entitled to all administrative costs permitted by the statute. It is also clear that Congress was sympathetic to taxpayers’ inability to obtain costs, in appropriate circumstances, that were incurred earlier than the time prescribed by section 7430(c)(2)(B). Congress, however, did not see fit to retroactively extend the modification of the period for recovery of additional administrative costs to the period of time within which petitioner incurred the costs in question. Accordingly, we are bound by Congress’s clear and unequivocal mandate. To reflect the foregoing, An order and decision will be entered granting respondent’s Motion For Summary Judgment and approving respondent’s notice of decision regarding the amount of costs to which petitioner is entitled.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011