Legal Opinion

Thomas C. Harrison and Rita Harrison v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided August 15, 1988No. 87-2350PublishedCited by 43 opinions

1Opinion of the Court

HARLINGTON WOOD, Jr., Circuit Judge.

Petitioners-appellants, Thomas C. Harrison and Rita Harrison (the Harrisons), filed a petition in the United States Tax Court in order to contest the purported deficiency set forth in a notice of deficiency issued by respondent-appellee, Internal Revenue Service (IRS), prior to completion of an audit. When the audit was eventually concluded, the IRS conceded that there was no deficiency due from the Harrisons. The Harri-sons then sought an award of litigation costs pursuant to section 7430 of the Internal Revenue Code, 26 U.S.C. § 7430. The Tax Court denied…

2Cases cited14 opinions

  1. Roberts v. CommissionerUnited States Tax Court · 1974
  2. Wasie v. CommissionerUnited States Tax Court · 1986
  3. Robert Randall Baker v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1986
  4. Baker v. CommissionerUnited States Tax Court · 1984
  5. Billy H. Ashburn and Faye F. Ashburn v. United StatesCourt of Appeals for the Eleventh Circuit · 1984

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

3Cited by43 opinions

  1. Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  2. Sokol v. CommissionerUnited States Tax Court · 1989
  3. Powers v. CommissionerUnited States Tax Court · 1993
  4. Bruce Hanson and Irene C. Hanson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
  5. Michael L. Lennox and Glenda J. Lennox v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993

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

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