James E. Blasius and Mary Jo Blasius, et al. - Page 1

                                 T.C. Memo. 2005-214                                  


                               UNITED STATES TAX COURT                                


            JAMES E. BLASIUS AND MARY JO BLASIUS, ET AL.1, Petitioners v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 4366-01, 4367-01,   Filed September 14, 2005.              
                           4368-01.                                                   


                    Ps and R have settled all issues in these                         
               consolidated cases save for Ps’ claims made pursuant to                
               sec. 7430, I.R.C., for recovery of administrative and                  
               litigation costs totaling $8,700.50.  Ps’ grounds for                  
               recovery are that R’s position in these proceeding with                
               respect to the capitalization of certain expenditures,                 
               which position R conceded before trial, was not                        
               substantially justified within the meaning of sec.                     
               7430(c)(4)(B)(i), I.R.C.                                               
                    Held:  R’s position with respect to the                           
               capitalization of the expenditures in question was                     
               substantially justified within the meaning of sec.                     


               1  Cases of the following petitioners are consolidated                 
          herewith:  Steven G. Balan, docket No. 4367-01, and Steven G.               
          Balan and Rachel Margules, docket No. 4368-01.                              





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