Sokol v. Commissioner
United States Tax Court
Prior to filing his answer to the petition herein, R tried to concede the tax issue raised in the deficiency notice and in the petition. Ps refused to execute a stipulated decision document because R would not concede Ps' entitlement to litigation costs under sec. 7430, I.R.C. 1954. In his answer to the petition, R conceded the only tax issue raised in the deficiency notice and in the petition.
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Prior to filing his answer to the petition herein, R tried to concede the tax issue raised in the deficiency notice and in the petition. Ps refused to execute a stipulated decision document because R would not concede Ps' entitlement to litigation costs under sec. 7430, I.R.C. 1954. In his answer to the petition, R conceded the only tax issue raised in the deficiency notice and in the petition. No further action was taken by either party until the case was called from a trial calendar for trial, at which time the parties filed a stipulation that there was no deficiency in or overpayment of…
1Opinion of the Court
Ronald M. and Nancy I. Sokol, Petitioners v. Commissioner of Internal Revenue, Respondent
Sokol v. Commissioner
Docket No. 18288-84
United States Tax Court
92 T.C. 760; 1989 U.S. Tax Ct. LEXIS 48; 92 T.C. No. 43;
April 5, 1989; As Amended April 6, 1989 April 5, 1989, Filed
Prior to filing his answer to the petition herein, R tried to concede the tax issue raised in the deficiency notice and in the petition. Ps refused to execute a stipulated decision document because R would not concede Ps' entitlement to litigation costs under sec. 7430, I.R.C. 1954. In his answer to the petition, R conceded the…
2Cases cited31 opinions
- Cupp v. CommissionerUnited States Tax Court · 1975
- BROAD AVENUE LAUNDRY AND TAILORING, Petitioner, v. the UNITED STATES, RespondentCourt of Appeals for the Federal Circuit · 1982
- Sher v. CommissionerUnited States Tax Court · 1987
- Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Sokol v. CommissionerUnited States Tax Court · 1989
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