- 4 -
petitioner conceded before trial.4 Additionally, this Court
found that there is no underpayment of tax for 1999 on which a
penalty may be imposed.
Petitioner filed a motion for award of litigation costs and
related costs. Petitioner seeks to recover either: (1) The
litigation costs incurred from the date of respondent’s issuance
of the notice of deficiency to petitioner through the date of
this Court’s issuance of its opinion, March 23, 2005, and related
costs, or (2) the litigation costs incurred for professional
services from the date petitioner made a qualified offer of
settlement, April 5, 2004, through the date of this Court’s
issuance of its opinion, March 23, 2005, and related costs.
Caspian has agreed to pay all litigation costs incurred on behalf
of petitioner, and Caspian is entitled to be reimbursed out of
any recovery of litigation costs that petitioner receives.
Petitioner also seeks to recover the costs incurred as a
result of bringing the motion for award of litigation costs and
related costs. Moreover, petitioner seeks to recover the costs
incurred as a result of preparing the reply to respondent’s
opposition to petitioner’s motion for award of litigation costs
and related costs.
4 Petitioner conceded before trial that he had failed to
report $227 of income on his 2000 return.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011