- 2 -
receiving a recommendation that P-Wife be granted
relief from R’s office that specializes in sec. 6015,
I.R.C., cases.
Held, further, P-Wife submitted a qualified offer
under sec. 7430(c)(4)(E) and (g), I.R.C., during the
qualified offer period, and P-Wife’s liability was
determined to be less than if R had accepted the
qualified offer.
Held, further, R’s concession was not a settlement
for purposes of sec. 7430(c)(4)(E)(ii), I.R.C.
Karen L. Hawkins, for petitioner Rhita S. Lippitz.
Paul E. Shick, for the Estate of Charles Lippitz.
James M. Klein, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: This matter is currently before the Court on
petitioner Rhita Lippitz’s motion for the recovery of litigation
costs. In relevant part petitioner1 alleged, and respondent
ultimately conceded, that she is entitled to relief under section
6015(c)2 from any additional joint liability determined for her
and her late husband Charles Lippitz for taxable years 1980
through 1985. Petitioner moves for the recovery of litigation
1For convenience, references to petitioner in the singular
are to Rhita Lippitz.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007