- 2 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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