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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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