- 2 - 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 butPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011