Thu Cuc Thi Huynh - Page 2




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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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