122 T.C. No. 14
UNITED STATES TAX COURT
VICTOR & JUDITH A. GRIGORACI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8784-01. Filed March 25, 2004.
Ps sought redetermination under sec. 6213, I.R.C., of
a deficiency for tax on self-employment income from a
partnership in which H was an indirect partner. Following
Grigoraci v. Commissioner, T.C. Memo. 2002-202 (Grigoraci
I), which involved a similar issue for Ps’ earlier tax year,
this Court dismissed the instant case for lack of
jurisdiction. Ps seek reasonable litigation and
administrative costs allegedly incurred in Grigoraci I as
well as in the instant proceeding. Ps also seek punitive
damages against R.
Held: Pursuant to sec. 7430, I.R.C., we cannot in this
proceeding award Ps litigation and administrative costs
incurred in connection with the proceedings in Grigoraci I.
Held, further, Ps have failed to establish that they
incurred litigation and administrative costs in this
proceeding apart from a $60 filing fee. Held, further, this
Court lacks jurisdiction to award punitive damages against
R.
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