Richard Scott Gehrs - Page 12

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          respondent’s Fresno Appeals Office.5  In short, section 6001                
          provides respondent with a reasonable basis in law to require               
          petitioner to file a tax return for 1997.                                   
               We hold that petitioner is not entitled to an award for                
          litigation costs because respondent’s position was substantially            
          justified.  In so holding, we have carefully considered the                 
          remaining arguments made by the parties, and, to the extent not             
          discussed above, we consider those arguments to be without merit.           
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               In order to reflect the foregoing,                                     


                                                  An appropriate order and            
                                             decision will be entered.                












               5  Respondent’s letter dated Oct. 5, 2000, to petitioner did           
          not make clear reference to sec. 6001.  However, the letter was             
          consistent with respondent’s other correspondence in informing              
          petitioner that respondent did not know what the original                   
          purchase price was with respect to the stocks and bonds sold in             
          1997.                                                                       





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