- 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