Kevin A. Goon - Page 2

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          decide is whether petitioner was the prevailing party.  For the             
          reasons stated below, we deny petitioner’s motion for reasonable            
               At the time of filing the petition in the instant case,                
          petitioner resided in Smyrna, Delaware.  Vanya Tyrrell (Mrs.                
          Tyrrell) prepared petitioner’s 2003 Form 1040, U.S. Individual              
          Income Tax Return (tax return).3                                            
               In the spring of 2005, respondent sent a letter to                     
          petitioner requesting that he submit documentation to support               
          certain deductions claimed on his 2003 tax return.  This was the            
          initial contact letter and did not provide petitioner an                    
          opportunity for administrative review with respondent’s Office of           
          Appeals.  Petitioner did not respond with the requested                     
          documentation.  Instead, petitioner’s attorney, Lowell E. Mann              
          (Mr. Mann), sent a letter protesting respondent’s proposed                  

          costs includes both administrative and litigation costs.  We                
          treat petitioner’s motion as a motion for both administrative and           
          litigation costs.                                                           
               2Unless otherwise indicated, all Rule references are to the            
          Tax Court Rules of Practice and Procedure, and all section                  
          references are to the Internal Revenue Code, as amended.                    
               3Petitioner’s tax return was one of approximately 175 tax              
          returns that were prepared by Vanya Tyrrell and chosen for                  
          examination by respondent’s Correspondence Examination Unit.  All           
          such cases involve similar unsubstantiated deductions.  Lowell E.           
          Mann represents the petitioners in all such cases and has filed             
          virtually identical petitions for each such case.                           

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