- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011