Pollei v. Commissioner
United States Tax Court
Ps petitioned this Court to contest R's determination that Ps' travel between their homes and office was commuting. Ps were unsuccessful in this Court and appealed to the Court of Appeals, which reversed and entered judgment for Ps. Because Ps were not the "prevailing [parties]" in this Court, they were precluded from seeking fees and costs under sec. 7430, I.R.C.
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Ps petitioned this Court to contest R's determination that Ps' travel between their homes and office was commuting. Ps were unsuccessful in this Court and appealed to the Court of Appeals, which reversed and entered judgment for Ps. Because Ps were not the "prevailing [parties]" in this Court, they were precluded from seeking fees and costs under sec. 7430, I.R.C. Following their successful appeal, Ps filed a motion with the Court of Appeals requesting that they be awarded their costs and attorneys' fees incurred during the appeal and that the appellate court issue an order directing "the…
1Opinion of the Court
Jon R. Pollei and Carol J. Pollei, Petitioners v. Commissioner of Internal Revenue, Respondent; Harry W. Patrick and Renee L. Patrick, Petitioners v. Commissioner of Internal Revenue, Respondent
Pollei v. Commissioner
Docket Nos. 28737-84, 28738-84
United States Tax Court
94 T.C. 595; 1990 U.S. Tax Ct. LEXIS 39; 94 T.C. No. 35;
April 18, 1990April 18, 1990, Filed
Ps petitioned this Court to contest R's determination that Ps' travel between their homes and office was commuting. Ps were unsuccessful in this Court and appealed to the Court of Appeals, which reversed and entered judgment for Ps.…
2Cases cited64 opinions
- Quern v. JordanSupreme Court of the United States · 1979
- Griggs v. Provident Consumer Discount Co.Supreme Court of the United States · 1982
- Marrese v. American Academy of Orthopaedic SurgeonsSupreme Court of the United States · 1985
- Commissioner v. FlowersSupreme Court of the United States · 1946
- In Re Sanford Fork & Tool Co.Supreme Court of the United States · 1895
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