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On May 15, 1999, respondent’s trial counsel requested
petitioners’ counsel to provide complete copies of portions of
the transaction documents that previously had not been provided
to respondent’s representatives.
On June 3, 1999, respondent rejected petitioners’ qualified
offer.
On June 16, 1999, the trial of the underlying substantive
tax issues in these consolidated cases was held in San Francisco,
California.
On June 21, 2000, we filed our Memorandum Opinion in Haas &
Associates Accountancy Corp. v. Commissioner, T.C. Memo. 2000-
183, and we held as follows:
(1) The $190,000 paid by Haas in connection with the
separation of the accounting practice and a covenant not to
compete was amortizable as an ordinary business expense
deduction over 3 years as claimed by petitioners on their
respective Federal income tax returns;
(2) The $63,500 paid by Haas allegedly for consulting
services represented a nondeductible startup expense that
required capitalization; and
(3) Because petitioners prevailed entirely on the treatment
of the $190,000 and because petitioners had a reasonable
basis for their claimed deduction for the $63,500 relating
to the consulting services, no accuracy-related penalties
were imposed on petitioners in connection with the above
Federal income tax returns that petitioners had filed.
In their motion for litigation costs, petitioners seek the
recovery of the following fees and costs incurred after the
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