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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