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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