T.C. Memo. 2002-282 UNITED STATES TAX COURT TAN DANG & KE T. CHAW DANG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6715-00. Filed November 14, 2002. Joyce Rebhun, for petitioners. Michael W. Berwind, for respondent. MEMORANDUM OPINION COLVIN, Judge: This matter is before the Court on petitioners’ motion for litigation costs under section 7430 and Rule 231. After concessions, the issues for decision are: 1. Whether respondent’s position in the underlying proceeding was substantially justified. We hold that it was not.Page: 1 2 3 4 5 6 7 8 9 10 Next
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