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respondent’s deficiency determination of $2,347.
After concessions by respondent,2 the issues for decision
are as follows:
(1) Whether respondent's position in the administrative and
court proceedings was substantially justified.
(2) Whether petitioner exhausted her administrative
remedies.
(3) Whether petitioner unreasonably protracted the
administrative and court proceedings.
(4) Whether the administrative and litigation costs claimed
by petitioner are reasonable.
Neither party requested an evidentiary hearing, and the
Court concludes that such a hearing is not necessary for the
proper disposition of petitioner’s motion. See Rule 232(a)(2).
We therefore decide the matter before us based on the record that
has been developed to date.
Petitioner resided in Alexandria, Virginia, at the time that
her petition was filed with the Court.
1(...continued)
was filed (Dec. 6, 2000). All Rule references are to the Tax
Court Rules of Practice and Procedure.
2 Respondent concedes: (1) Petitioner substantially
prevailed, see sec. 7430(c)(4)(A)(i); and (2) petitioner
satisfied the applicable net worth requirement, see sec.
7430(c)(4)(A)(ii).
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