Gary Gealer - Page 2

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          adopts the opinion of the Special Trial Judge which is set forth            
                         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.                       
               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             

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