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respondent’s deficiency determination of $4,328.2
After concessions by respondent,3 the issues for decision
are as follows:
(1) Whether respondent’s position in the administrative and
court proceedings was substantially justified.
(2) Whether petitioner unreasonably protracted the
administrative and court proceedings.
(3) Whether the administrative and litigation costs claimed
by petitioner are reasonable.
Neither party requested an evidentiary hearing, and the
Court concludes that such a hearing is not necessary for the
proper disposition of petitioner’s motion. See Rule 232(a)(2).
We therefore decide the matter before us based on the record that
has been developed to date.
Background
Petitioner resided in Hyattsville, Maryland, at the time
that his petition was filed with the Court.
Petitioner timely filed a Federal income tax return for the
1(...continued)
section in effect at the time that the petition was filed.
Unless otherwise indicated, all Rule references are to the Tax
Court Rules of Practice and Procedure.
2 All amounts have been rounded.
3 Respondent concedes: (1) Petitioner substantially
prevailed, see sec. 7430(c)(4)(A)(i); and (2) petitioner
satisfies the applicable net worth requirement, see sec.
7430(c)(4)(A)(ii).
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Last modified: May 25, 2011