Corson v. Comm'r
United States Tax Court
P was an investor in a partnership involved in tax shelter litigation in this Court. In 1985, P entered into settlement agreements with R, pursuant to which P could not deduct losses in excess of payments he had made to or on behalf of the partnership for taxable years before 1980 or after 1982. In 1999, after the partnership litigation concluded, R assessed additional income tax and accrued interest for P's taxable year 1983 attributable to P's involvement in the…
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P was an investor in a partnership involved in tax shelter litigation in this Court. In 1985, P entered into settlement agreements with R, pursuant to which P could not deduct losses in excess of payments he had made to or on behalf of the partnership for taxable years before 1980 or after 1982. In 1999, after the partnership litigation concluded, R assessed additional income tax and accrued interest for P's taxable year 1983 attributable to P's involvement in the partnership. P filed a claim for abatement of the interest. During P's correspondence conference with R, P provided to R a copy of…
1Opinion of the Court
OPINION
Marvel, Judge:
This case is before the Court on petitioner’s motion for reasonable litigation costs filed pursuant to section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time petitioner filed the petition, and all Rule references are to the Tax Court Rules of Practice and Procedure. Petitioner resided in Saratoga, California, when his petition in this case was filed.
On December 12, 2003, we filed the parties’ stipulation of settled issues1 and petitioner’s motion for reasonable litigation costs. On February 11,…
2Cases cited12 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Clair S. Huffman v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
- Minahan v. CommissionerUnited States Tax Court · 1987
- Sokol v. CommissionerUnited States Tax Court · 1989
- Krause v. CommissionerUnited States Tax Court · 1992
7 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Hinck v. United StatesUnited States Court of Federal Claims · 2005
- Goettee v. Comm'rUnited States Tax Court · 2005
- Corson v. Comm'rUnited States Tax Court · 2009
- Vasquez v. Comm'rUnited States Tax Court · 2007
- Jones v. Comm'rUnited States Tax Court · 2008
17 more not listed; retrieve them via the Exa API.