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