-10-
return each signed that return declaring under penalties of
perjury that he or she had “examined this return” and that it was
“true, correct, and complete”.5
We hold that petitioner does not qualify for an award of
litigation costs under section 7430. We have considered all
arguments for a contrary holding and find those arguments not
discussed herein to be irrelevant, without merit, or improperly
raised in petitioner’s reply to respondent’s objection. To
reflect the foregoing,
An appropriate order will be
issued, and decision will be entered in
accordance with the parties’ settlement.
5 Petitioner also relies erroneously on the fact that
respondent knew before issuing the notice of deficiency that
petitioner had at least at one time resided at 629 Mariola. As
stated above, the reporting of the 4302 Callahan address on the
2001 return made that address petitioner’s address of record at
all relevant times thereafter.
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Last modified: May 25, 2011