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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
reference.
After concessions,2 the issues for decision are whether
petitioner unreasonably protracted the proceedings and whether
the costs claimed are reasonable.
Background
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:
Penalty
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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