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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On June 2, 2000, in an unpublished opinion the Court of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.
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