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of the documents that had been provided by decedent’s accountant
to respondent’s examination office and Appeals Office, and
respondent’s trial counsel initiated telephone conversations with
employees of the Nevada casinos concerning the documentation that
had been provided, as a result of which respondent’s trial
counsel concluded that decedent in 2000 incurred with regard to
his gambling activities, and was entitled to deduct in full, the
total $2,580,200 in gambling losses claimed on decedent’s 2000
Federal income tax return.
On or about February 28, 2005, the parties entered into a
settlement under the terms of which it was agreed that the
$2,092,364 in gambling losses that had been disallowed by
respondent in respondent’s notice of deficiency would be conceded
by respondent.
Also, as part of the settlement, it was agreed that no claim
would be made by the estate for the recovery of litigation costs,
but the estate reserved the right to make a claim for
administrative costs.
On March 28, 2005, the estate filed the instant motion for
recovery of $1,657.50 in administrative costs, plus additional
costs of prosecuting the instant motion.
Respondent agrees that under the settlement that was entered
into the estate substantially prevailed with regard to the amount
in controversy.
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