Wayne and Lois Hampton - Page 2




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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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