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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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