Paul Frehe Enters. v. Commissioner
United States Tax Court
Petitioner moved for award of reasonable litigation costs in a so-called actuarial case. Held, respondent's position was substantially justified. Held, further, petitioner's motion for award of reasonable litigation costs is denied.
1Opinion of the Court
PAUL FREHE ENTERPRISES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Paul Frehe Enters. v. Commissioner
Docket No. 22080-91.
United States Tax Court
106 T.C. 436; 1996 U.S. Tax Ct. LEXIS 29; 106 T.C. No. 25; 20 Employee Benefits Cas. (BNA) 1413;
June 13, 1996, Filed
An order denying petitioner's Motion for Award of Reasonable Litigation Costs and a decision in accordance with the settlement stipulation of the parties will be entered.
Petitioner moved for award of reasonable litigation costs in a so-called actuarial case. Held, respondent's position was substantially justified.…
2Cases cited9 opinions
- Clair S. Huffman v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
- Vinson & Elkins, J. Evans Attwell, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
- Wachtell, Lipton, Rosen & Katz, David M. Einhorn, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Citrus Valley Estates v. CommissionerUnited States Tax Court · 1992
- Jerome Mirza & Associates, Ltd., an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1989
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