- 6 - respondent another settlement offer, this time offering to settle for full relief under section 6015(c) from any additional joint liability. In the same letter petitioner indicated to respondent that she intended to file a motion for summary judgment if respondent did not agree to the settlement. Respondent did not agree to the settlement, and on May 24, 2006, petitioner filed a motion for summary judgment. On July 14, 2006, respondent moved for additional time to respond to petitioner’s motion and indicated an intention to concede petitioner’s entitlement to the relief recommended from CCISO. Respondent sought additional time in order to pursue a stipulation of settled issues reflective of his concession. At this point, petitioner refused to enter into a stipulation of settled issues. In a subsequent filing related to respondent’s motion to extend time, respondent indicated to the Court that he in fact conceded the innocent spouse issue. On September 21, 2006, this Court determined that petitioner’s motion for summary judgment was moot because respondent conceded. Petitioner now moves for the recovery of litigation costs. Petitioner argues that for the period of July 28, 2004, to the present, she is entitled to an award of litigation fees because she is the prevailing party and respondent was not substantially justified. For the period July 2, 2005, to the present, petitioner argues that she is entitledPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007