- 2 - petitioner is entitled to the costs of litigating his Federal tax liability for the years 1990, 1991, 1992, and 1993 after he conveyed a purported qualified offer in a letter to respondent dated April 27, 2004. We hold that the letter of April 27, 2004, was a qualified offer and that petitioner is entitled to his litigation costs paid or incurred after conveying this offer. Background The underlying facts of this case are set forth in detail in Jondahl v. Commissioner, T.C. Memo. 2005-55. We briefly revisit some of the factual and procedural background to rule on the instant motion. Respondent determined deficiencies in petitioner’s 1990, 1991, 1992, and 1993 Federal income taxes of $25,438, $2,883, $9,883, and $35,876, respectively. Respondent also determined fraud penalties under section 6663 for 1990, 1991, 1992, and 1993 of $19,078.50, $2,162.25, $7,412.25, and $26,907, respectively. Respondent sent a notice of deficiency to petitioner on May 22, 2002. On August 20, 2002, petitioner timely filed a petition in this Court challenging respondent’s determinations. On April 27, 2004, petitioner sent respondent a letter indicating his willingness to settle this litigation and purporting to convey a qualified offer under section 7430(g). In part, petitioner wrote: The taxpayer, as his qualified offer, agrees to establish as the taxpayer’s liability (determinedPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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