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information. Petitioner declined to respond. The documents
provided by petitioner in a letter dated September 27, 2000,
while helpful, did not invalidate respondent’s position. More
documentation was necessary for petitioner to establish that he
was entitled to the claimed filing status, deductions, and
credit. We note that, when petitioner did bring the necessary
documents on November 18, 2002, the case was quickly resolved.
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.
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Last modified: May 25, 2011