Estate of Dooley v. Commissioner
United States Tax Court
Respondent (R) determined over $ 8 million of deficiencies in, and additions to, the income, estate, and gift taxes of petitioners -- Mrs. Dooley and the estate of her deceased husband. Prior to trial, R conceded most of the factual issues and settled the three cases for a total of $ 143,787 in gift tax.
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Respondent (R) determined over $ 8 million of deficiencies in, and additions to, the income, estate, and gift taxes of petitioners -- Mrs. Dooley and the estate of her deceased husband. Prior to trial, R conceded most of the factual issues and settled the three cases for a total of $ 143,787 in gift tax. Petitioners (Ps) moved for an award of litigation costs pursuant to sec. 7430, I.R.C. 1954, arguing, inter alia, that R was not substantially justified in adhering to her litigating positions on the substantive tax issues. Held: Given the complex and convoluted nature of these cases, R was…
1Opinion of the Court
ESTATE OF OGDEN D. DOOLEY, DECEASED, WILLIE JO DOOLEY, EXECUTRIX, AND WILLIE JO DOOLEY, SURVIVING WIFE, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Dooley v. Commissioner
Docket Nos. 11131-88, 23026-88, 23027-88
United States Tax Court
T.C. Memo 1992-557; 1992 Tax Ct. Memo LEXIS 577; 64 T.C.M. (CCH) 824;
September 22, 1992, Filed
Respondent (R) determined over $ 8 million of deficiencies in, and additions to, the income, estate, and gift taxes of petitioners -- Mrs. Dooley and the estate of her deceased husband. Prior to trial, R conceded most of the factual…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- 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
- Minahan v. CommissionerUnited States Tax Court · 1987
- De Venney v. CommissionerUnited States Tax Court · 1985
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