Jose A. Salazar - Page 4




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          docket No. 12440-00, challenging respondent’s determination.2               
               On December 8, 2000, petitioner filed with respondent an               
          application for administrative costs for 1982, 1983, 1984, and              
          1985 under section 7430.  On December 15, 2000, respondent wrote            
          to petitioner informing him that his application for                        
          administrative costs for 1982 and 1983 was premature in light of            
          his then-pending petition for review of his interest abatement              
          claim in docket No. 12440-00.  Respondent did not otherwise                 
          respond to petitioner’s request for reimbursement of                        
          administrative costs for 1984 and 1985.                                     
               On March 19, 2001, petitioner filed with the Court a                   
          petition for administrative costs, which was assigned docket No.            
          3806-01, seeking a recovery for 1984 and 1985.  On October 23,              
          2001, the Court entered an order of dismissal for lack of                   
          jurisdiction in docket No. 3806-01 on the ground that the                   
          petition was not filed with respect to a decision of the Internal           
          Revenue Service granting or denying an application for reasonable           
          administrative costs pursuant to section 7430(f)(2),3 nor had the           


               2  On Oct. 22, 2001, the Court entered a stipulated decision           
          in docket No. 12440-00 in which the parties agreed that                     
          petitioner was entitled to partial abatements of interest for               
          1982 and 1983 resulting in overpayments of interest of $1,785 and           
          $2,561, for 1982 and 1983, respectively.                                    
               3  Sec. 7430(f)(2) provides that a taxpayer may file a                 
          petition for review with the Court challenging a decision of the            
          Internal Revenue Service granting or denying (in whole or in                
          part) an award for reasonable administrative costs.  Generally,             
                                                             (continued...)           





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