- 2 - Code in effect at the time petitioners filed the petition, and all Rule references are to the Tax Court Rules of Practice and Procedure. When the petition in this case was filed, petitioners’ mailing address was in Whitethorn, California. On October 20, 2003, the day this case was calendared for trial, the parties filed a stipulation of settled issues. On October 31, 2003, petitioners filed their motion for reasonable litigation costs. After obtaining an extension of time in which to respond, on February 2, 2004, respondent filed an objection to petitioners’ motion. On February 17, 2004, petitioners filed an additional affidavit pursuant to Rule 232(d). Neither party requested a hearing, and we have concluded that a hearing on this matter is not necessary. See Rule 232(a)(2). In disposing of this motion, we rely on the parties’ filings and attached exhibits. Background During 2002, petitioners were selected for audit. In a letter to respondent dated August 9, 2002, on behalf of petitioners, Roland Potter, C.P.A., addressed certain proposed adjustments to petitioners’ income tax. Mr. Potter did not enclose any documents with the letter. As an attachment to a letter dated January 9, 2003, respondent sent to petitioners Form 4549A, Income Tax Examination Changes, for petitioners’ 1999, 2000, and 2001 taxable years.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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