- 2 - remedies and are not eligible for an award of litigation costs under sec. 7430, I.R.C. William Edward Taggart, Jr., for petitioners. Kathryn K. Vetter, for respondent. SUPPLEMENTAL FINDINGS OF FACT AND OPINION SWIFT, Judge: This matter is before us on petitioners’ motion under Rule 231 for an award of $44,559 in litigation costs and fees under the general provisions of section 7430 and under the qualified offer rule of section 7430(c)(4)(E) and (g). In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes and accuracy- related penalties as follows: 1993 1994 1995 Michael and Angela Haas Tax Deficiency $34,416 -- –- Sec. 6662(a) Accuracy- Related Penalty 6,883 -- -- Haas & Associates Accountancy Corp. Tax Deficiency -- $10,833 $7,457 Sec. 6662(a) Accuracy- Related Penalty -- 2,167 1,491 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011