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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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