T.C. Memo. 2003-136 UNITED STATES TAX COURT JAMES L. AND SHERRI R. GOERTLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3121-01. Filed May 13, 2003. R determined a deficiency in Ps’ tax for 1998 based on their failure to substantiate deductions for personal exemptions under sec. 151(c), I.R.C., with respect to persons claimed as dependents. Ps filed a petition for redetermination, and R subsequently conceded the entire case. Ps seek recovery of costs in the amount of $880 pursuant to sec. 7430, I.R.C. Held: R’s position in the proceeding at issue was substantially justified within the meaning of sec. 7430(c)(4)(B)(i), I.R.C., thereby precluding Ps’ recovery of costs under that section. James L. and Sherri R. Goertler, pro sese. Thomas J. Travers, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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