Estate of Wall v. Commissioner
United States Tax Court
P filed a motion pursuant to Rule 231, Tax Court Rules of Practice and Procedure and sec. 7430, I.R.C., seeking reasonable administrative and litigation costs, claiming that R's position was not substantially justified. Held, R's position was substantially justified for purposes of sec. 7430, I.R.C.
1Opinion of the Court
SUPPLEMENTAL OPINION
NlMS, Judge:
The parties have previously been before this Court, and we have issued our opinion on that matter in Estate of Wall v. Commissioner, 101 T.C. 300 (1993). We incorporate our opinion by this reference. Petitioner has timely filed a motion for an award of reasonable administrative and litigation costs pursuant to Rule 231 and section 7430.
All Rule references are to the Tax Court Rules of Practice and Procedure and, except as otherwise noted, all section references are to sections of the Internal Revenue Code in effect at all times relevant to this case.
The facts…
2Cases cited5 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Stephen P. Wilfong v. United StatesCourt of Appeals for the Seventh Circuit · 1993
- Archbold Van Beuren v. Martin M. McLoughlin (Former Acting Collector of Internal Revenue), DefendnatsCourt of Appeals for the First Circuit · 1959
- Corning v. CommissionerUnited States Tax Court · 1955
- Estate of Wall v. CommissionerUnited States Tax Court · 1993
3Cited by13 opinions
- Price v. CommissionerUnited States Tax Court · 1994
- Charles E. Nicholson, Jr. And Margaret K. Nicholson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1995
- Newman v. Comm'rUnited States Tax Court · 2012
- Vines v. Comm'rUnited States Tax Court · 2006
- Downing v. Comm'rUnited States Tax Court · 2005
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