Kennedy v. Commissioner
United States Tax Court
Ps filed a motion for award of litigation costs. Ps are dairy farmers who used the cash method of accounting. R commenced a Taxpayer Compliance Measurement Program (TCMP) examination of Ps' dairy business activities and determined adjustments to income of Ps and Ps' partnerships which were based largely on R's change of the accounting method employed by Ps from the cash method to the accrual method.
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Ps filed a motion for award of litigation costs. Ps are dairy farmers who used the cash method of accounting. R commenced a Taxpayer Compliance Measurement Program (TCMP) examination of Ps' dairy business activities and determined adjustments to income of Ps and Ps' partnerships which were based largely on R's change of the accounting method employed by Ps from the cash method to the accrual method. After R issued notices of deficiency to Ps incorporating the TCMP determinations, these cases were settled by stipulation of the parties. The determinations agreed upon in the respective…
1Opinion of the Court
OPINION
WILLIAMS, Judge:
These consolidated cases are before the Court on petitioners’ motion for award of litigation costs pursuant to section 7430.2
The Commissioner determined deficiencies in petitioners’ Federal income taxes as follows:
Docket No. TYE Dec. 31-Deficiency
4308-85 1980 $135,273.81
4541-85 1980 314.63
1981 4,372.58
1982 7,332.02
4557-85 1981 103,552.70
4558-85 1980 1,950.87
1981 1,402.96
1982 216.91
5639-85 1980 640.48
This Court must decide, for purposes of section 7430, (1) whether petitioners exhausted their administrative remedies; and (2) whether the position of the United States in…
2Cases cited15 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Minahan v. CommissionerUnited States Tax Court · 1987
- United States v. CattoSupreme Court of the United States · 1966
- Robert Randall Baker v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1986
10 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Harris v. CommissionerUnited States Tax Court · 1988
- Kennedy v. CommissionerUnited States Tax Court · 1987
- King Solarman, Inc. v. CommissionerUnited States Tax Court · 2019
- Laurel Alterman & William A. Gibson v. CommissionerUnited States Tax Court · 2018