Michael and Tanya Neylan - Page 3

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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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