Cozean v. Commissioner
United States Tax Court
Prior to trial, R conceded the deficiencies determined for the years 1990 through 1992. P filed a timely claim for an award of litigation costs, including, among other things, attorney's fees billed at $<>250 per hour and one accountant's fees billed at $<>170 and $<>175 per hour and another's fees billed at $<>90 and $<>92 per hour.
Read the full summary
Prior to trial, R conceded the deficiencies determined for the years 1990 through 1992. P filed a timely claim for an award of litigation costs, including, among other things, attorney's fees billed at $<>250 per hour and one accountant's fees billed at $<>170 and $<>175 per hour and another's fees billed at $<>90 and $<>92 per hour. R concedes that P has satisfied all the requirements for entitlement to litigation costs and disputes only the amounts of the fees claimed by the attorney and the principal accountant. Specifically, R asserts that the limitation of sec. 7430(c)(1)(B)(iii),…
1Opinion of the Court
OPINION
Dawson, Judge:
The case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge: This case is before the Court on petitioner’s motion for an award of reasonable litigation costs 2 pursuant to section 7430.
Respondent concedes that petitioner has satisfied all of the requirements for entitlement to litigation costs. Therefore, the only issue…
2Cases cited12 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Minahan v. CommissionerUnited States Tax Court · 1987
- Zulema De La Garza Perales, Cross-Appellants v. Richard Casillas, Cross-AppelleesCourt of Appeals for the Fifth Circuit · 1992
- Powers v. CommissionerUnited States Tax Court · 1993
7 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Foothill Ranch Co. Pshp. v. CommissionerUnited States Tax Court · 1998
- TERRELL EQUIP. CO. v. COMMISSIONERUnited States Tax Court · 2002
- Vasquez v. Comm'rUnited States Tax Court · 2007
- Caspian Consulting Group v. Comm'rUnited States Tax Court · 2006
- Chapman v. Comm'rUnited States Tax Court · 2009
11 more not listed; retrieve them via the Exa API.