- 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
Last modified: May 25, 2011