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adjustments and requesting that the case be transferred to
respondent’s Appeals Office. Because petitioner failed to submit
the requested documentation substantiating the disputed
deductions, respondent determined a deficiency of $750 in income
tax for 2002 and sent petitioner a notice of deficiency on
June 13, 2005.
Mr. Mann sent a letter to respondent requesting that
respondent rescind the notice of deficiency. Respondent did not
rescind the notice of deficiency, and petitioner timely filed his
petition in this Court on September 6, 2005. Respondent filed
his answer on October 25, 2005. By notice dated November 10,
2005, the instant case was placed on the April 3, 2006, calendar
in Philadelphia, Pennsylvania.
On February 18, 2006, Ms. Tyrrell sent documentation to
support the deductions in question to Mr. Mann, who forwarded it
to respondent’s Appeals officer. At the call of the instant case
from the Philadelphia trial session calendar on April 3, 2006,
the parties filed a stipulation of settled issues, which
indicated respondent’s concession and a reduced deficiency of
$480. In the instant motion, petitioner now seeks $3,152.50 in
administrative and litigation costs.
Discussion
The prevailing party in a Tax Court proceeding may be
entitled to recover administrative and litigation costs. See
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Last modified: May 25, 2011