- 18 - here discuss whether respondent’s position was “substantially justified”, whether petitioners unreasonably protracted the proceedings, or whether petitioners’ claimed costs are unreasonable or excessive. Also, we do not consider whether or to what extent the analysis in Fla. Country Clubs, Inc. v. Commissioner, 122 T.C. 73 (2004), affd. 404 F.3d 1291 (11th Cir. 2005), relating to deficiency cases, applies in interest abatement cases. For the above reasons, we hold petitioners are not entitled to litigation costs. To reflect the foregoing, An appropriate order and decision will be entered denying petitioners’ motion for award of litigation costs, as supplemented, and determining overpayments in accordance with the filed joint Rule 155 computations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011