125 T.C. No. 2
UNITED STATES TAX COURT
KENNETH C. RATHBUN, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 14383-03, 14384-03, Filed July 12, 2005.
14385-03, 14387-03,
14391-03.
Ps seek administrative costs for expenses incurred in
administrative proceedings with R regarding the 1993 taxable
year. Ps contend that a letter issued by R in December of
1995 constitutes a notice of the decision of the Internal
Revenue Service Office of Appeals and R’s position in the
administrative proceedings as provided by sec.
7430(c)(7)(B), I.R.C.
Held: The letter issued by R in December of 1995 is
not a notice of the decision of the Internal Revenue Service
1Cases of the following petitioners are consolidated
herewith: Doreen M. and Marc R. Fretwell, docket No. 14384-03;
Charles E. and Gladythe M. Rathbun, docket No. 14385-03; Linda J.
and Arlen R. Johnson, docket No. 14387-03; and Jana B. Rathbun-
Hanley, docket No. 14391-03.
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