- 4 -
On January 16, 2003, petitioners filed a motion for entry of
decision in this case on the basis of this Court’s holding in
Grigoraci I. In their motion, petitioners asserted that in this
case, as in Grigoraci I, the related partnership-level proceeding
had not been completed. In his response, filed February 7, 2003,
respondent stated that he had no objection to petitioners’ motion
for entry of decision. On March 26, 2003, this Court entered an
order of dismissal for lack of jurisdiction, denying petitioners’
motion for entry of decision and dismissing this case for lack of
jurisdiction, consistent with this Court’s jurisdictional holding
in Grigoraci I.4
On May 9, 2003, petitioners filed a motion for reasonable
litigation and administrative costs, with supporting affidavits.
On August 1, 2003, respondent filed his response. Pursuant to
this Court’s Order dated September 22, 2003, on November 6, 2003,
petitioners filed additional supporting affidavits and a reply to
respondent’s response. On December 15, 2003, respondent filed a
response to petitioners’ last-mentioned filing.
3(...continued)
in Grigoraci I that the Grigoracis properly reported this income
as wages from the S corporation and owed no self-employment tax
on it.
4 By Order dated May 9, 2003, we vacated our order of
dismissal for lack of jurisdiction entered Mar. 26, 2003, pending
resolution of petitioners’ motion for reasonable litigation and
administrative costs.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011