Caspian Consulting Group, Inc. - Page 2

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          for an evidentiary hearing on this matter.  See Rule 232(a)(2).             
          Accordingly, we rule on petitioner’s motion on the basis of the             
          parties’ submissions and the existing record.  See Rule                     
          232(a)(1).  The portions of our opinion on the merits in the                
          instant case, Caspian Consulting Group, Inc. v. Commissioner,               
          T.C. Memo. 2005-54 (Caspian I), that are relevant to our                    
          disposition of this motion are incorporated herein by this                  
               After concessions,2 the issues for decision are whether                
          petitioner unreasonably protracted the proceedings and whether              
          the costs claimed are reasonable.                                           
               Respondent issued a notice of deficiency to petitioner on              
          July 24, 2003, determining the following deficiencies in and                
          accuracy-related penalty on petitioner’s Federal income taxes:              
               Year      Deficiency     Sec. 6662(a)                                  
               1999      $2,133         –                                             
               2000      43,698         $8,740                                        
               On October 22, 2003, petitioner timely petitioned this Court           
          conceding the deficiencies for both years and asking the Court to           
          redetermine only the accuracy-related penalty for the year 2000.            

               2  Respondent concedes that petitioner is the prevailing               
          party due to the qualified settlement offer, meets the net worth            
          requirements, and exhausted petitioner’s administrative remedies.           

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