Tae M. and Young J. Kim - Page 2

                                        - 2 -                                         
               On May 8, 1997, respondent issued to petitioners a notice of           
          deficiency (notice) determining a deficiency in, and an accuracy-           
          related penalty under section 6662(a)1 on, their Federal income             
          tax for each of the years 1993 and 1994.  Petitioners timely                
          filed a petition with respect to that notice (Kim I), and a trial           
          was held in Kim v. Commissioner, docket No. 15447-97.  On August            
          4, 1999, the Court filed its opinion in Kim I.  Kim v. Commis-              
          sioner, T.C. Memo. 1999-261.   Thereafter, petitioners did not              
          file a motion in Kim I claiming reasonable administrative and/or            
          litigation costs.  On December 1, 1999, the Court entered a                 
          decision in Kim I.                                                          
               In February 2000, petitioners appealed the decision of the             
          Court in Kim I to the United States Court of Appeals for the                
          Fourth Circuit (Court of Appeals).                                          
               On March 23, 2000, respondent issued to petitioners two                
          separate notices, entitled “Notice of Tax Due on Federal Tax                
          Return”, one of which pertained to petitioners’ taxable year 1993           
          and one of which pertained to petitioners’ taxable year 1994.               
               On June 2, 2000, in an unpublished opinion the Court of                
          Appeals affirmed the Court’s decision in Kim I.  Kim v. Commis-             
          sioner, 215 F.3d 1319 (4th Cir. 2000), affg. per curiam without             
          published opinion T.C. Memo. 1999-261.                                      

               1All section references are to the Internal Revenue Code in            
          effect at all relevant times.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011