- 2 -
adopts the opinion of the Special Trial Judge which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge: This case is before the Court
pursuant to petitioner's motion for administrative and litigation
costs under section 7430 and Rules 230 through 232.
Petitioner seeks to recover administrative and litigation
costs of $237,618.15, allegedly incurred in contesting
respondent's determination of an income tax deficiency of $36,565
and a penalty of $7,313 for the taxable year 1995.
Petitioner filed his motion for administrative and
litigation costs on March 2, 2000. Respondent filed an objection
to petitioner's motion, petitioner filed a reply to respondent's
objection, and respondent filed a response to petitioner's reply.
In accordance with Rule 232(a), we will dispose of the
motion before us without a hearing. Accordingly, we rule on
petitioner's motion on the basis of the parties' submissions and
the record in this case. The underlying issues raised in the
petition were settled by a stipulation of settlement.
Background
At the time the petition in this case was filed, petitioner
resided in Los Angeles, California.
Much of the $237,618.15 of administrative and litigation
costs petitioner seeks and much of the voluminous record do not
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011