James Tinnell - Page 2

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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).                    
               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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