Victor & Judith A. Grigoraci - Page 13

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          clerical in nature.  More fundamentally, even if we were to                 
          assume, for sake of argument, that Ms. Lyons and Ms. West acted             
          as petitioners’ representatives, this circumstance would be                 
          insufficient to meet the section 7430 requirement that the cost             
          of their services be “incurred”.  See Kruse v. Commissioner,                
          supra; Thompson v. Commissioner, T.C. Memo. 1996-468.                       
               In conclusion, petitioners have failed to show that they               
          “incurred” the claimed administrative personnel expenses or the             
          associated miscellaneous expenses.  Moreover, they have                     
          acknowledged that most of the claimed administrative personnel              
          expenses relate to the Grigoraci I proceedings and have failed to           
          establish how much of the claimed miscellaneous expenses relates            
          to this proceeding.  We have found that only $60 of the claimed             
          filing fees relates to the instant proceedings.  Giving effect to           
          respondent’s concession, we hold that petitioners are entitled to           
          an award of $60 for these filing fees.                                      
          E.  Punitive Damages                                                        
               Petitioners also request that we award punitive damages                
          against respondent.  There is no statutory authority for this               
          Court to consider petitioners’ claim for punitive damages against           
          the Internal Revenue Service; consequently, we have no                      











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