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respondent’s deficiency determination for the taxable years 1991
through 1994.
The issues for decision are whether petitioner qualifies as
a “prevailing party” for purposes of section 7430 and, if so,
whether the litigation costs petitioner seeks are adequately
documented and are reasonable, and whether petitioner has
unreasonably protracted the Court proceedings. Neither
petitioner nor respondent requested an evidentiary hearing, and
we conclude that such a hearing is not necessary for the proper
disposition of petitioner’s motion. See Rule 232(a)(2).
Background
The following facts are based upon the entire record,
including the affidavits and exhibits submitted by the parties
with respect to petitioner’s motion for costs, the parties’
pleadings and stipulations of settled issues, the stipulations of
fact, and related documents.
Petitioner, a businessman and licensed physician, resided in
Las Vegas, Nevada, when the petition in this case was filed on
October 9, 1997.
During the relevant periods, petitioner conducted a mining
activity known as Jetco Enterprises, the financial results of
which he reported on Schedules C, Profit or Loss From Business,
of his respective tax returns. For each of the years at issue,
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