Kevin A. Goon - Page 3

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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 $5,325 in                 
          income tax for 2003 and sent petitioner a notice of deficiency on           
          June 6, 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 19, 2005.  By notice dated November 10,               
          2005, the instant case was placed on the April 3, 2006, calendar            
          in Philadelphia, Pennsylvania.                                              
               On March 16, 2006, petitioner forwarded a portion of the               
          requested documentation 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 partial concession             
          and a reduced deficiency of $1,050.  In the instant motion,                 
          petitioner now seeks $2,267.50 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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