Michael E. Bowles Lynn G. Bowles v. United States
Court of Appeals for the Fourth Circuit
1Opinion of the Court
OPINION
WILKINS, Circuit Judge:
Michael E. and Lynn G. Bowles appeal an order of the district court denying their motion for an award of costs and attorney’s fees pursuant to section 7430 of the Internal Revenue Code. I.R.C. § 7430 (1982). Concluding that the district court did not abuse its discretion in determining that the position of the government in this civil proceeding was not unreasonable, we affirm.
I
Appellants are a married couple who were employed by Pan American World Airways. They were assigned to duty in New York City and maintained a residence there. They also maintained a…
2Cases cited11 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Commissioner v. FlowersSupreme Court of the United States · 1946
- 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
- David Kaufman v. Roscoe Egger, Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1985
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3Cited by17 opinions
- In Re Billie Vester Rasbury, Debtor. Billie Vester Rasbury Bill's Forestry Service, Inc. v. Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1994
- Howard's Yellow Cabs, Inc. v. United StatesDistrict Court, W.D. North Carolina · 1997
- Stephen P. Wilfong v. United StatesCourt of Appeals for the Seventh Circuit · 1993
- Hiep H. Dang Phuong My T. Chau v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2001
- Pittman v. United StatesDistrict Court, E.D. North Carolina · 1994
12 more not listed; retrieve them via the Exa API.