Legal Opinion
Bouterie v. Commissioner
Court of Appeals for the Fifth Circuit
Decided November 7, 1994No. 93-05534PublishedCited by 21 opinions
1Opinion of the Court
WIENER, Circuit Judge:
Petitioner-Appellant Rita B. Bouterie (“Taxpayer”) appeals an order of the United States Tax Court (“Tax Court”) denying her request for the costs incurred in litigating a Petition for Redetermination of Taxes (“Petition for Redetermination”), which she filed in response to a Notice of Deficiency (“Notice”) issued by the IRS. The Tax Court found that Taxpayer had failed to establish that the IRS’ litigation position was not “substantially justified” and thus held that Taxpayer was not entitled to costs pursuant to 26 U.S.C. § 7430. We find to the contrary that Taxpayer…
2Cases cited26 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Christiansburg Garment Co. v. Equal Employment Opportunity CommissionSupreme Court of the United States · 1978
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- United States v. MitchellSupreme Court of the United States · 1971
- David J. Powell and the Estate of Jeane D. Powell, Deceased, David J. Powell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
21 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Nalle v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Marre' v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Marsha Hatch Ingham v. United StatesCourt of Appeals for the Ninth Circuit · 1999
- Faramarz Fayeghi and Shelli Fayeghi,petitioners-Appellants v. Commissioner of Internal Revenue,respondent-AppelleeCourt of Appeals for the Ninth Circuit · 2000
- White v. Missouri Veterinary Medical BoardMissouri Court of Appeals · 1995
16 more not listed; retrieve them via the Exa API.