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