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Victor & Judith A. Grigoraci, pro sese.
Mary Ann Waters, for respondent.
OPINION
THORNTON, Judge: This case is before us on petitioners’
motion for reasonable litigation and administrative costs
pursuant to section 7430 and Rule 231.1
Background
Mr. Grigoraci is a certified public accountant and the chief
executive officer (C.E.O.) of an accounting partnership,
Grigoraci, Trainer, Wright & Paterno (GTWP). On December 1,
1995, Mr. Grigoraci formed Victor Grigoraci CPA Accounting Corp.
as an S corporation (the S corporation) for the purpose of acting
as a partner (with two other corporations) in GTWP. On their
1997 and 1998 joint Federal income tax returns, petitioners
reported certain distributions from the S corporation,
essentially representing passthroughs to Mr. Grigoraci of the S
corporation’s distributive shares of GTWP’s income.
By notice of deficiency dated April 13, 2001, respondent
determined that the amounts petitioners had reported as the S
corporation’s distributions actually represented Mr. Grigoraci’s
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure. All references
to sec. 7430 are to that section as in effect when the petition
was filed.
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