Goettee v. Comm'r
United States Tax Court
Ps claimed investment credits and losses arising out of a partnership in which they held a limited interest. By notice of deficiency, R disallowed these claimed credits and losses. Ps accepted a settlement offer from R and paid all deficiencies and additions reflected in the entered decision. Ps requested abatement of interest on these amounts. R initially disallowed the abatement request in full, then later allowed partial abatement.
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Ps claimed investment credits and losses arising out of a partnership in which they held a limited interest. By notice of deficiency, R disallowed these claimed credits and losses. Ps accepted a settlement offer from R and paid all deficiencies and additions reflected in the entered decision. Ps requested abatement of interest on these amounts. R initially disallowed the abatement request in full, then later allowed partial abatement. Ps then paid the remaining assessed interest liabilities. Ps petitioned this Court to review R's disallowance of interest abatements. After R's concessions, we…
1Opinion of the Court
OPINION
Chabot, Judge:
This matter is before us on petitioners’ motion for an award of reasonable litigation costs pursuant to section 74301 and Rule 231.2
The issues for decision are:(1) Whether petitioners are the “prevailing party” for purposes of section 7430 — in particular:
(A) whether petitioners “substantially prevailed” with respect to either the most significant issue or set of issues or the amount in controversy, within the meaning of section 7430(c)(4)(A)(i), or
(B) whether respondent established that respondent’s position was “substantially justified” within the meaning of section…
2Cases cited8 opinions
- Minahan v. CommissionerUnited States Tax Court · 1987
- Fla. Country Clubs, Inc. v. Comm'rUnited States Tax Court · 2004
- Dixson Int'l Service Corp. v. CommissionerUnited States Tax Court · 1990
- Corson v. Comm'rUnited States Tax Court · 2004
- Scrimgeour v. Internal RevenueCourt of Appeals for the Fourth Circuit · 1998
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Images in Motion of El Paso, Inc. v. Comm'rUnited States Tax Court · 2006
- Vasquez v. Comm'rUnited States Tax Court · 2007
- Jones v. Comm'rUnited States Tax Court · 2008
- Elder v. Comm'rUnited States Tax Court · 2007
- Goettee v. Comm'rUnited States Tax Court · 2005
2 more not listed; retrieve them via the Exa API.