James L. and Sherri R. Goertler - Page 2

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                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  This case is before the Court on                      
          petitioners’ motion for costs (the motion) pursuant to section              
          7430 and Rules 230 through 233.1  Petitioners seek to recover               
          costs in the amount of $880 incurred in connection with                     
          respondent’s determination of a deficiency in tax with respect to           
          their taxable (calendar) year 1998.2  Respondent objects.                   
          Neither party requested an evidentiary hearing, and we conclude             
          that such a hearing is not necessary for the proper disposition             
          of the motion.  See Rule 232(a)(2).  Accordingly, we shall                  
          proceed on the basis of the parties’ submissions.  For the                  
          reasons discussed below, we shall deny the motion.                          
                          Factual and Procedural Background                           
               Petitioners are husband and wife residing in Camas,                    
          Washington.  Petitioners made a joint return of Federal income              
          tax for 1998 by filing a Form 1040, U.S. Individual Income Tax              
          Return (1998 return).  Petitioners’ certified public accountant             
          (C.P.A.), David Austen, prepared the 1998 return.  On the 1998              
          return, petitioners claimed deductions (the section 151(c)                  


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               2  Petitioners initially sought to recover costs in the                
          amount of $1,000.  After conferring with respondent pursuant to             
          Rule 232(c), petitioners reduced the amount of costs for which              
          they seek recovery to $880.                                                 




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