- 12 - In the Court’s Opinion, the Court addressed the $622 inter- est determination, the $16 Travelers Prop. determination, the $8 WSB interest determination, petitioners’ alleged capital gain issue, and petitioners’ alleged capital loss issue. In the Court’s Opinion, the Court held for respondent on all of the foregoing issues except the $8 WSB interest determination. In petitioners’ motion and the affidavit attached thereto, petitioners claimed the following litigation costs (claimed litigation costs): Tax Court filing fee: $60.00 Mailing costs: $90.15 Delivery fee: $330.00 Consultation costs: $2,900.00 Document preparation: $640.45 Parking fee: $96.40 Transportation: $647.50 Telephone calls: $82.40 Petitioners did not provide any additional information with respect to the claimed litigation costs. Discussion As pertinent here, section 7430(a) authorizes an award to the prevailing party of reasonable litigation costs incurred in connection with a case brought in the Court against the Commis- sioner of Internal Revenue (Commissioner) involving the determi- nation of any tax, interest, or penalty under the Code. The term “prevailing party” means, in general, any party who (1) has substantially prevailed with respect to (a) the amount in contro- versy, sec. 7430(c)(4)(A)(i)(I), or (b) the most significantPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007