- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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