- 2 - 7430(c)(4)(B)(i), I.R.C., with the result that Ps’ are not entitled to recovery under sec. 7430(a), I.R.C. Erwin A. Rubenstein and Nicole R. Tennenhouse, for petitioners. Eric R. Skinner and Phoebe L. Nearing, for respondent. MEMORANDUM OPINION HALPERN, Judge: These cases (the consolidated cases, or, when referred to prior to consolidation, the cases) are before the Court on petitioners’ motions for litigation and administrative fees and costs (the motions) filed October 9, 2002.2 The motions are made pursuant to section 7430 and Rules 230 through 233.3 Petitioners seek to recover (1) attorney’s fees of $7,131 and costs of $182 in connection with respondent’s determinations of deficiencies in tax with respect to petitioners’ taxable (calendar) years 1996, 1997, and 1998 (the audit years),4 (2) attorney’s fees of $1,357.50 incurred through August 31, 2002, in connection with filing the motions, plus (3) 2 On Oct. 23, 2002, petitioners moved to consolidate the cases for purposes of disposing of the motions, which motions to consolidate were granted on Nov. 18, 2002. 3 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. 4 Docket No. 4366-01 involves calendar years 1996, 1997, and 1998. Docket No. 4367-01 involves calendar year 1996. Docket No. 4368-01 involves calendar years 1997 and 1998.Page: Previous 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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