- 18 - Since the penalty equaled 20 percent of the alleged underpayment attributable to the discharge of indebtedness issue, the ratio of nonrecoverable costs to recoverable costs is 5:1. Applying that ratio to petitioners’ eligible costs of $8,697.49, we determine that petitioners are entitled to recover $1,449.58. IV. Summary We find that (1) respondent’s position with respect to the discharge of indebtedness issue was substantially justified, (2) respondent’s position with respect to the imposition of the accuracy-related penalty was not substantially justified, and (3) the amount of petitioners’ recoverable costs allocable to the penalty issue is $1,449.58. To reflect the foregoing, An appropriate order and decision will be entered. 13(...continued) taxpayers prevailed in that endeavor).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011