- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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