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of Maryland for both Lilly Phan and Anna Phan.6
A hearing was held on petitioner’s motion for summary
judgment on August 28, 2002.
Following the hearing with this Court, respondent forwarded
the certified copies of the Affidavits of Parentage and birth
certificates to the assigned Appeals officer. After receiving
these documents, respondent settled the case within 2 weeks.
On October 23, 2002, petitioner filed his motion for an
award of costs. On January 22, 2003, respondent filed an
objection to petitioner’s motion for an award of costs.
Thereafter, on March 14, 2003, petitioner filed a reply, and on
April 21, 2003, respondent filed a response.
Discussion
We apply section 7430 as amended by Congress in the Internal
Revenue Service Restructuring and Reform Act of 1998 (RRA 1998),
Pub. L. 105-206, sec. 3101, 112 Stat. 727.7
6 The certified copies of the Affidavits of Parentage are
signed by the State Registrar of Vital Records with the following
declaration: “I HEREBY CERTIFY THAT THE ATTACHED IS A TRUE COPY
OF A RECORD ON FILE IN THE DIVISION OF VITAL RECORDS”. The
certified copies of the affidavits are stamped “VALID ONLY WITH
IMPRESSED SEAL”.
7 Sec. 7430 was amended most recently by Congress in the
Community Renewal Tax Relief Act of 2000 (CRTRA), Pub. L. 106-
554, sec. 319(25), 114 Stat. 2763A-647. The amendment, which is
effective on the date of enactment of CRTRA (Dec. 21, 2000),
affects only sec. 7430(c)(3) and is purely clerical in nature.
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