Legal Opinion

Dixson Int'l Service Corp. v. Commissioner

United States Tax Court

Decided May 17, 1990No. 22832-88PublishedCited by 27 opinions

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

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Sher v. CommissionerUnited States Tax Court · 1987
  3. Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  4. Minahan v. CommissionerUnited States Tax Court · 1987
  5. Sokol v. CommissionerUnited States Tax Court · 1989

18 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Powers v. CommissionerUnited States Tax Court · 1993
  2. Nalle v. CommissionerUnited States Tax Court · 1994
  3. Estate of Hubberd v. CommissionerUnited States Tax Court · 1992
  4. Bragg v. CommissionerUnited States Tax Court · 1994
  5. Goettee v. Comm'rUnited States Tax Court · 2005

22 more not listed; retrieve them via the Exa API.

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