Grigoraci v. Comm'r
United States Tax Court
Ps sought redetermination under sec. 6213, I.R.C., of a deficiency for tax on self-employment income from a partnership in which H was an indirect partner. Following Grigoraci v. Commissioner, T.C. Memo. 2002-202 (Grigoraci I), which involved a similar issue for Ps' earlier tax year, this Court dismissed the instant case for lack of jurisdiction. Ps seek reasonable litigation and administrative costs allegedly incurred in Grigoraci I as well as in the instant proceeding.
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Ps sought redetermination under sec. 6213, I.R.C., of a deficiency for tax on self-employment income from a partnership in which H was an indirect partner. Following Grigoraci v. Commissioner, T.C. Memo. 2002-202 (Grigoraci I), which involved a similar issue for Ps' earlier tax year, this Court dismissed the instant case for lack of jurisdiction. Ps seek reasonable litigation and administrative costs allegedly incurred in Grigoraci I as well as in the instant proceeding. Ps also seek punitive damages against R. Held: Pursuant to sec. 7430, I.R.C., we cannot in this proceeding award Ps…
1Opinion of the Court
OPINION
Thornton, Judge:
This case is before us on petitioners’ motion for reasonable litigation and administrative costs pursuant to section 7430 and Rule 231.1
Background
Mr. Grigoraci is a certified public accountant and the chief executive officer (C.E.O.) of an accounting partnership, Grigoraci, Trainer, Wright & Paterno (GTWP). On December 1, 1995, Mr. Grigoraci formed Victor Grigoraci CPA Accounting Corp. as an S corporation (the S corporation) for the purpose of acting as a partner (with two other corporations) in GTWP. On their 1997 and 1998 joint Federal income tax returns, petitioners…
2Cases cited8 opinions
- David E. Gantner and Sandra L. Gantner v. Commissioner of Internal Revenue, David E. Gantner and Sandra L. Gantner v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
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- Gantner v. CommissionerUnited States Tax Court · 1989
- Weiss v. CommissionerUnited States Tax Court · 1987
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