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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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