Legal Opinion

Florida Country Clubs, Inc. v. Comm. of IRS

Court of Appeals for the Eleventh Circuit

Decided March 31, 2005No. 04-12302PublishedCited by 3 opinions

1Opinion of the Court

SILER, Circuit Judge:

Introduction

Taxpayers Florida Country Clubs, Inc., and Suncoast Country Clubs, Inc., both Subchapter S corporations, and James R. Mikes and Deborah A. Hamilton appeal the tax court’s determination that they are not entitled to recover costs under 26 U.S.C. § 7430. Because the tax court correctly found that the United States did not take a position in this case, and because the Taxpayers concede that they may not recover costs if the United States did not take a position, we AFFIRM.

Background

In December 1995, the IRS began an audit of Florida Country Clubs, Inc. for the…

2Cases cited5 opinions

  1. Thomas W. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2003
  2. Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
  3. Robert Fehlhaber v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1992
  4. Corbett v. FrankCourt of Appeals for the Ninth Circuit · 1961
  5. Coggin Automotive Corporation v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 2002

3Cited by3 opinions

  1. Rathbun v. Comm'rUnited States Tax Court · 2005
  2. Kenneth C. Rathbun v. CommissionerUnited States Tax Court · 2005
  3. Rathbun v. Comm'rUnited States Tax Court · 2005

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