Dixson Int'l Service Corp. v. Commissioner
United States Tax Court
R took several alternative positions in the notices of deficiency and answers, but did not explicitly identify them as such. When these cases were called for trial, the parties filed stipulations of settled issues and requested additional time to make the computations necessary for entry of decisions. Neither the stipulations of settled issues nor the oral representations of the parties made any reference to litigation costs.
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R took several alternative positions in the notices of deficiency and answers, but did not explicitly identify them as such. When these cases were called for trial, the parties filed stipulations of settled issues and requested additional time to make the computations necessary for entry of decisions. Neither the stipulations of settled issues nor the oral representations of the parties made any reference to litigation costs. The stipulations of settled issues involved substantial concessions by both parties. The final computations show that Ps' combined net tax deficiencies, pursuant to the…
1Opinion of the Court
OPINION
RUWE, Judge:
Respondent, in two separate notices of deficiency, determined the following deficiencies in petitioners’ corporate income taxes:
Dixson International Service Corp.
Docket No. 22829-88
TYE Deficiency
Sept. 30, 1977. $130,279
Dixson, Inc. & Subsidiaries
Docket No. 22832-88
TYE Deficiency
Sept. 30, 1974 $62,600
Sept. 30, 1975 125,189
Sept. 30, 1976 21,149
Sept. 30, 1977 461,952
Sept. 30, 1978 49,710
This matter is before the Court on petitioners’ motions for litigation costs pursuant to Rule 2312 and section 7430.
Dixson, Inc., & Subsidiaries (Dixson) is a corporation organized and existing…
2Cases cited23 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sher v. CommissionerUnited States Tax Court · 1987
- Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Minahan v. CommissionerUnited States Tax Court · 1987
- Sokol v. CommissionerUnited States Tax Court · 1989
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3Cited by27 opinions
- Powers v. CommissionerUnited States Tax Court · 1993
- Nalle v. CommissionerUnited States Tax Court · 1994
- Estate of Hubberd v. CommissionerUnited States Tax Court · 1992
- Bragg v. CommissionerUnited States Tax Court · 1994
- Goettee v. Comm'rUnited States Tax Court · 2005
22 more not listed; retrieve them via the Exa API.