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adjustments and requesting that the case be transferred to
respondent’s Appeals Office. Because petitioners failed to
submit the requested documentation substantiating the disputed
deductions, respondent determined a deficiency of $1,830 in
income for 2003 and sent petitioners a notice of deficiency on
June 13, 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 petitioners timely filed
their petition in this Court on September 6, 2005. Respondent
filed his answer on October 17, 2005. By notice dated November
10, 2005, the instant case was placed on the April 3, 2006,
calendar in Philadelphia, Pennsylvania.
On March 15, 2006, Ms. Tyrrell sent documentation to support
the deductions in question to Mr. Mann. Respondent’s Appeals
officer received the documentation from petitioners’ counsel on
March 21, 2006. 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 concession and a reduced deficiency of $473. In the
instant motion, petitioners now seek $3,437.50 in administrative
and litigation costs.
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Last modified: May 25, 2011