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indicated, section references are to sections of the Internal
Revenue Code in effect at all relevant times hereunder.
References to section 7430 are to the version of that section in
effect at the time the petition was filed. However, costs
incurred on or before January 18, 1999, are subject to section
7430 as amended by the Taxpayer Relief Act of 1997, Pub. L. 105-
34, secs. 1285, 1453, 111 Stat. 1038, 1055. Costs incurred after
January 18, 1999, are subject to section 7430 as amended by the
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3101, 112 Stat. 727.
Rule references are to the Tax Court Rules of Practice and
Procedure.
Pursuant to section 7443A and Rules 180 and 183, this matter
was assigned to and heard by Special Trial Judge Lewis R.
Carluzzo. His recommended findings of fact and conclusions of
law were filed and served upon the parties by Order of July 5,
2005.
By the abovementioned Order, the parties were also given
until August 31, 2005, to make specific written objections to the
Special Trial Judge’s recommended findings of fact and
conclusions of law. In response thereto, respondent filed a
timely Notice of No Objection. Petitioners timely filed 26 pages
of Objections to Recommendations (Objections).
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Last modified: November 10, 2007