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