Legal Opinion
Kenneth C. Rathbun v. Commissioner
United States Tax Court
Decided July 12, 2005No. 14383-03, 14384-03, 14385-03, 14387-03, 14391-03Unknown
1Opinion of the Court
125 T.C. No. 2
UNITED STATES TAX COURT KENNETH C. RATHBUN, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 14383-03, 14384-03, Filed July 12, 2005. 14385-03, 14387-03, 14391-03. Ps seek administrative costs for expenses incurred in administrative proceedings with R regarding the 1993 taxable year. Ps contend that a letter issued by R in December of 1995 constitutes a notice of the decision of the Internal Revenue Service Office of Appeals and R’s position in the administrative proceedings as provided by sec. 7430(c)(7)(B), I.R.C. Held: The letter issued by R in…
2Cases cited5 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Fla. Country Clubs, Inc. v. Comm'rUnited States Tax Court · 2004
- Rathbun v. Comm'rUnited States Tax Court · 2005
- Florida Country Clubs, Inc. v. Comm. of IRSCourt of Appeals for the Eleventh Circuit · 2005