117 T.C. No. 5
UNITED STATES TAX COURT
HAAS & ASSOCIATES ACCOUNTANCY CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
MICHAEL A. HAAS AND ANGELA M. HAAS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16486-98, 16487-98. Filed August 10, 2001.
Held: Evidence excluded at trial may be
considered by the Court in ruling under sec. 7430,
I.R.C., on a motion for litigation costs.
Held, further, a “qualified offer” made under sec.
7430(c)(4)(E) and (g), I.R.C., does not satisfy the
requirement under sec. 7430(b)(1), I.R.C., that in
order to qualify for an award of litigation costs a
taxpayer is required to exhaust available
administrative remedies.
Held, further, under the facts of these cases,
petitioners did not exhaust their administrative
* This opinion supplements our prior Memorandum Opinion, Haas
& Associates Accountancy Corp. v. Commissioner, T.C. Memo. 2000-
183.
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