James L. and Sherri R. Goertler - Page 1

                                 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.                                     

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