- 2 - Petitioners requested that respondent administratively abate the addition to tax under section 6651(a)(2) for failure to pay tax for 1993, 1995, and 1996. Respondent denied their request on January 13, 2000. The parties later settled the case, with respondent conceding the issue for 1993 and petitioners conceding 1995 and 1996. Petitioners seek $8,162.50 in administrative costs. After concessions, the issue for decision is whether respondent's position in the administrative proceeding was substantially justified. We hold that it was. References to petitioner are to Dennis Flynn. FINDINGS OF FACT Some of the facts were stipulated and are so found. A. Petitioners Petitioners were married and resided in Stockton, California, when they filed the petition. At all relevant times, petitioner was a tenured professor at the University of the Pacific in Stockton, California, and petitioner Nancy Flynn was employed as an administrator by the Tracy, California, public school system. 1. Petitioners’ Bankruptcy in 1991-92 Petitioner was a general partner in a ministorage partnership beginning in 1986. The ministorage business and petitioners filed petitions in bankruptcy and received ordersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011