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been proposed by the Appeals officer.
At calendar call (March 20, 2000), the parties filed a
stipulation in which they resolved all of the issues raised in
the notice of deficiency. The stipulation did not differ from
the settlement offers that the Appeals and District Counsel
offices previously had made. Specifically, the parties
stipulated that for 1998: (1) Petitioner is not entitled to any
dependency exemptions for his three children; (2) petitioner is
not entitled to head of household filing status, but rather to
single filing status; and (3) petitioner is entitled to an earned
income credit in the amount claimed by petitioner on his 1998
Federal income tax return, based on two qualifying children. The
stipulation resulted in a tax deficiency of $448 for 1998.
At calendar call, petitioner also filed a motion for an
award of reasonable administrative and litigation costs (motion
for costs), requesting an award of $1,837.45. Subsequently,
petitioner filed a supplement to the motion for costs in which he
raised his previous request to $2,335.11.
On May 4, 2000, respondent filed a response to petitioner’s
motion for costs and supplement thereto. In the response,
respondent disputed petitioner’s allegations that respondent’s
position was not substantially justified, that petitioner did not
unreasonably protract the proceedings, and that the costs
requested were reasonable.
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