T.C. Memo. 2006-118 UNITED STATES TAX COURT TIMOTHY J. COBURN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6695-04. Filed June 8, 2006. Richard A. Siegal and Mark S. Gregory, for petitioner. Michael J. Proto, for respondent. MEMORANDUM OPINION WELLS, Judge: The instant matter is before the Court on petitioner’s motion for litigation fees and costs pursuant to section 7430 and Rule 231. The issues to be decided are whether respondent’s position in the court proceeding was substantially justified and whether the litigation costs petitioner claims arePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011