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After concessions, the remaining issue for decision is
whether petitioners are entitled under section 7430 to an award
of $12,339 in litigation costs.
FINDINGS OF FACT
At the time the petition was filed, petitioners resided in
Watts, Oklahoma.
On December 27, 1996, respondent began an audit of
petitioners’ 1994 Federal income tax liability.
On April 15, 1997, as a result of petitioners’ failure to
attend several scheduled appointments with respondent’s revenue
agent and to provide respondent with requested records,
respondent issued to petitioners a 30-day letter with regard to
petitioners’ 1994 Federal income tax liability.
Petitioners filed with respondent’s Appeals Office a protest
to the above 30-day letter. Because petitioners represented to
the Appeals Office that they possessed records for 1994 that they
had not yet provided to respondent’s revenue agent, respondent’s
Appeals Office returned petitioners’ case to respondent’s
Examination Division for review of the additional records that
petitioners offered to provide.
Over the next 12 months, progress was made by petitioners
and respondent’s revenue agent towards an agreement of
petitioners’ 1994 Federal income tax liability. Petitioners
provided to respondent additional records relating to some but
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